State Court Discovery - Interrogatories - Oregon

OREGON INTERROGATORIES — DO NOT SERVE

Discovery-Method Conversion Worksheet

Current official ORCP 36 A lists these discovery methods:

• depositions on oral examination or written questions;
• production of documents or things, or permission to enter land or other property for inspection and other purposes;
• physical and mental examinations; and
• requests for admission.

Party-served written interrogatories are not included. This file therefore is not a discovery request, does not create a response deadline, and must not be captioned or served as interrogatories in an Oregon circuit-court action.

Use this worksheet only to organize factual topics for Oregon counsel to convert into an authorized discovery device under the current ORCP, the court's scheduling order, and any case-specific order.

1. CASE INFORMATION

2. METHOD SELECTION

For each topic below, Oregon counsel should select an authorized method and prepare the separate document required for that method.

• ☐ Deposition on oral examination
• ☐ Deposition on written questions
• ☐ Request for production or inspection
• ☐ Physical or mental examination request or motion, if applicable
• ☐ Request for admission
• ☐ Informal disclosure request permitted by agreement or order
• ☐ Other authorized procedure: [________________________________]

Do not assume that a question suitable for an interrogatory in another jurisdiction can be copied verbatim into an Oregon request for admission, production request, or deposition notice.

3. FACT AND WITNESS TOPICS

3.1 Persons with Knowledge

Identify the persons believed to have knowledge of the claims or defenses, the subject of each person's knowledge, and the authorized method counsel will use to obtain the information.

3.2 Claim and Defense Contentions

4. DOCUMENT AND ESI TOPICS

List the records sought without converting this worksheet into a production request.

• ☐ Communications concerning the events at issue
• ☐ Contracts, policies, procedures, and retention schedules
• ☐ Photographs, video, audio, and social-media content
• ☐ Medical, employment, accounting, or transaction records relevant to pleaded issues
• ☐ Investigation, audit, or incident records
• ☐ Insurance agreements or policies potentially responsive under current ORCP 36 B(2)
• ☐ Electronically stored information and relevant custodians
• ☐ Other: [________________________________]

5. ADMISSION TOPICS

Draft only narrow propositions that counsel determines are appropriate for a current ORCP request for admission.

6. DEPOSITION TOPICS

• Witness or organization: [________________________________]
• Proposed oral or written-question format: [________________________________]
• Subjects for examination: [________________________________]
• Documents to coordinate with the deposition: [________________________________]
• Court order or stipulation needed: [________________________________]

7. COUNSEL REVIEW CHECKLIST

• ☐ Confirm the current official ORCP edition and any amendments effective before service.
• ☐ Confirm the selected method is authorized for this case.
• ☐ Confirm the court's scheduling order and discovery cutoff.
• ☐ Confirm service, response, objection, and motion deadlines for the selected method.
• ☐ Review proportionality, privilege, work-product, privacy, and protective-order issues.
• ☐ Prepare a separate, method-specific discovery document.
• ☐ Do not serve this worksheet.

SOURCES AND REFERENCES

• Oregon Legislature, Oregon Rules of Civil Procedure (current official compilation): https://www.oregonlegislature.gov/bills_laws/SiteAssets/ORCP.html
• ORCP 36 A, “Discovery methods” (same official compilation)

IMPORTANT: Oregon does not list party interrogatories among the discovery methods in ORCP 36 A. This worksheet is an internal planning aid only and is not a discovery request.