IN THE CIRCUIT COURT OF THE STATE OF OREGON
FOR THE COUNTY OF [COUNTY]

[PLAINTIFF NAME],
Plaintiff, Case No. [____]

v. PLAINTIFF’S FIRST SET OF
INTERROGATORIES TO
[DEFENDANT NAME], DEFENDANT [DEFENDANT NAME]
Defendant.

Date of Service: [DATE]

GENERAL RECITALS

Pursuant to the Oregon Rules of Civil Procedure (“ORCP”), the applicable Scheduling/Case Management Order, and all other applicable rules and laws, Plaintiff propounds the following Interrogatories to Defendant [DEFENDANT NAME]. Each Interrogatory is to be answered separately, fully, and in writing under oath within thirty (30) days after service, unless the parties stipulate or the Court orders otherwise.

[// GUIDANCE: ORCP currently imposes no specific numerical limit on interrogatories. Practitioners should nevertheless keep the “proportionality” standard of ORCP 36 in mind and be prepared to justify scope and burden if challenged.]

TABLE OF CONTENTS

I. Definitions & Instructions....................................... 2
II. Interrogatories.................................................. 4
III. Verification (to be completed by responding party)............... 11
IV. Certificate of Service.......................................... 12

I. DEFINITIONS & INSTRUCTIONS

A. Definitions
1. “You,” “Your,” or “Defendant” means [DEFENDANT NAME], all current and former parents, subsidiaries, affiliates, divisions, officers, directors, employees, agents, representatives, attorneys, and any other Person acting on its behalf.
2. “Document” has the broadest meaning permissible under ORCP and includes, without limitation, all written, printed, typed, recorded, graphic, photographic, or electronic matter—including ESI (electronically stored information)—of every kind.
3. “Communication” means any transmission of information, whether oral, written, electronic, or otherwise.
4. “Identify” (when referring to a Person) means to state the Person’s full name, present or last known address, telephone number, and relationship to the Parties.
5. “Person” means any natural person, corporation, partnership, association, joint venture, governmental body, or any other legal or business entity.
6. “ESI” means electronically stored information of any kind—including but not limited to emails, text messages, instant messages, social-media content, database records, metadata, and all other digital data—maintained in any medium from which information can be retrieved.

B. Instructions
1. Each Interrogatory must be answered separately, completely, and under oath.
2. If You contend that any Interrogatory is objectionable in whole or in part, state the specific grounds and answer the remainder.
3. If You withhold information based on any privilege, expressly identify the privilege claimed and provide a privilege log sufficient to allow Plaintiff and the Court to assess the claim.
4. These Interrogatories are continuing. If You obtain additional responsive information, You must promptly serve supplemental answers.
5. Unless a specific date is otherwise indicated, the relevant time period is [START DATE] through the present.
6. Whenever necessary to bring an answer within the scope of an Interrogatory, “and” as well as “or” shall be read in the conjunctive and in the disjunctive, “any” shall mean “all,” and the singular shall include the plural (and vice versa).

[// GUIDANCE: Practitioners commonly add detailed ESI protocols or incorporate existing ESI stipulations by reference here.]

II. INTERROGATORIES

Interrogatory No. 1
Identify each Person who prepared, supplied information for, or assisted in preparing Your responses to these Interrogatories, and state the subject matter of the information each such Person provided.

Interrogatory No. 2
Identify every Person known to You who has knowledge of any facts relevant to the claims or defenses in this action, and for each such Person state the subject matter of his or her knowledge.

Interrogatory No. 3
State in detail the factual basis for each denial set forth in Your responsive pleadings.

Interrogatory No. 4
State in detail the factual basis for each affirmative defense asserted in Your responsive pleadings.

Interrogatory No. 5
Describe every Communication between You and Plaintiff (or any agent of Plaintiff) concerning the subject matter of this lawsuit, identifying the date, participants, and substance of each Communication.

Interrogatory No. 6
Identify all Documents upon which You rely to support Your defenses, and for each such Document state the Bates number (if available), date, author, and a brief description of its contents.

Interrogatory No. 7
Describe all damages You contend were caused by Plaintiff, including the method of calculation and identification of all supporting Documents.

Interrogatory No. 8
Identify all insurance agreements (primary, excess, umbrella, or otherwise) that may satisfy any part of a judgment entered against You in this action, specifying the insurer, policy number, limits, and applicable endorsements.

Interrogatory No. 9
Identify all Persons whom You expect to call as expert witnesses at trial, and for each such Person state the subject matter on which the expert is expected to testify and a summary of the grounds for each opinion.

Interrogatory No. 10
Describe with particularity the steps You have taken to preserve Documents and ESI potentially relevant to this action, including the date any litigation-hold notice was issued and the custodians covered.

Interrogatory No. 11
State the full name, present or last known address, and present or last known employer of every Person who was employed by You and involved in the events alleged in the Complaint.

Interrogatory No. 12
Describe all internal investigations, audits, or reviews conducted by You relating to the allegations in the Complaint, and identify all Documents generated as a result.

Interrogatory No. 13
Identify all social-media accounts (including usernames or handles) maintained by You, or by any employee whose conduct is at issue in this lawsuit, that contain posts, messages, or other content concerning Plaintiff or the subject matter of this action.

Interrogatory No. 14
Describe in detail any repairs, modifications, or remedial measures undertaken by You after the incident(s) alleged in the Complaint, identifying the date, nature, and cost of each such measure.

Interrogatory No. 15
If You contend that any third party is responsible, in whole or in part, for the damages alleged by Plaintiff, identify each such third party and state the factual basis for Your contention.

Interrogatory No. 16
State the complete factual basis for each counterclaim asserted by You, including a description of all Documents and Communications that support each counterclaim.

Interrogatory No. 17
Identify each governmental or regulatory investigation relating to the subject matter of this action that involved You, and describe the outcome of each investigation.

Interrogatory No. 18
Describe the organizational structure (including parent, subsidiary, and affiliate relationships) of [DEFENDANT NAME] during the relevant time period.

Interrogatory No. 19
Identify all retention schedules, policies, or procedures governing the preservation or destruction of Documents or ESI that were in effect during the relevant time period.

Interrogatory No. 20
State the factual basis for Your contention (if any) that Plaintiff failed to mitigate damages, including identification of all supporting Documents.

Interrogatory No. 21
Identify all contracts, agreements, or understandings between You and Plaintiff that relate in any way to the claims asserted in this action.

Interrogatory No. 22
Describe each instance in which You contended that Plaintiff breached any contractual or legal obligation to You, identifying the date, nature of the alleged breach, and any resulting damages.

Interrogatory No. 23
Identify all witnesses You intend to call at trial (other than experts identified in Interrogatory No. 9) and provide a summary of the expected testimony of each witness.

Interrogatory No. 24
Describe any alternative dispute resolution efforts (including settlement discussions or mediations) undertaken by the Parties concerning the subject matter of this action.

Interrogatory No. 25
State all facts supporting each element of any defense based on statute of limitations, laches, or other time-based bar, and identify all Documents evidencing those facts.

[// GUIDANCE: Remove, add, or tailor interrogatories to suit the factual and procedural posture of your particular case. Consider using contention interrogatories closer to the discovery-cutoff date.]

III. VERIFICATION

STATE OF __ )
) ss.
COUNTY OF ___ )

I, [NAME OF PERSON VERIFYING], being first duly sworn, depose and say: I am [position/title] of [DEFENDANT NAME]; I have read the foregoing Answers to Interrogatories and know the contents thereof; the same are true and correct to the best of my knowledge, information, and belief.

[NAME]
[Title]
[DEFENDANT NAME]

Subscribed and sworn to before me this ___ day of ____, 20__.

Notary Public for __
My Commission Expires: ____

[// GUIDANCE: Oregon requires that interrogatory answers be signed under oath by the party—not merely by counsel. Add a corporate attestation if the responding party is an entity.]

IV. CERTIFICATE OF SERVICE

I hereby certify that on the ___ day of ____, 20__, I served the foregoing PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT [DEFENDANT NAME] on the following counsel of record by [U.S. Mail / hand delivery / electronic service pursuant to UTCR 21.100 / other method]:

[NAME, address, e-mail]

DATED this ___ day of ____, 20__.

[ATTORNEY NAME], OSB No. [_]
Attorney for Plaintiff
[LAW FIRM NAME]
[Address]
[Phone] | [Email]

[// GUIDANCE:
1. Discovery Limits – Oregon currently imposes no fixed limit on the number of interrogatories, but be prepared to defend the proportionality and burden of the requests under ORCP 36.
2. Response Deadlines – Unless otherwise stipulated or ordered, responses are due 30 days after service (add three days for mailing per ORCP 10 C).
3. Privilege Rules – When withholding information, identify the privilege and produce a log sufficient to allow assessment. Oregon generally recognizes attorney-client, work-product, and other privileges codified in the Oregon Evidence Code (e.g., ORS 40.225 et seq.).
4. E-service – If you intend to serve discovery electronically, ensure compliance with Uniform Trial Court Rule (UTCR) 21. Obtain written consent or court order if required.
5. Supplemental Responses – ORCP 36 E imposes a continuing duty to supplement if responses become incomplete or incorrect.
]