Rhode Island State Court Discovery Interrogatories

RHODE ISLAND STATE COURT DISCOVERY INTERROGATORIES

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS

[________________________________] SUPERIOR COURT

[________________________________],

Plaintiff,

v.

C.A. No.: [________________________________]

[________________________________],

Defendant.

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT

ATTORNEY INFORMATION

TABLE OF CONTENTS

1. Introductory Statement and Authority
2. Definitions
3. Instructions
4. General Interrogatories (Nos. 1-20)
5. Case-Specific Interrogatories
6. Verification / Oath
7. Certificate of Service
8. Practice Notes
9. Sources and References

I. INTRODUCTORY STATEMENT AND AUTHORITY

Plaintiff, [________________________________] ("Plaintiff"), by and through undersigned counsel, hereby propounds the following Interrogatories upon Defendant, [________________________________] ("Defendant"), pursuant to Rule 33 of the Rhode Island Superior Court Rules of Civil Procedure ("R.I. Super. R. Civ. P." or "R.I. R. Civ. P.").

Response Deadline. Pursuant to R.I. R. Civ. P. 33(b), Defendant must serve written, sworn answers and any objections within thirty (30) days after service of these Interrogatories. A different time period may be directed by the Court or agreed to by the parties under R.I. R. Civ. P. 29.

Interrogatory Limit. Pursuant to R.I. R. Civ. P. 33(a), a party may serve no more than thirty (30) interrogatories upon an adverse party, including all parts and sub-parts, without leave of court. This set contains [____] interrogatories (including all discrete sub-parts), which does not exceed the permitted limit.

Continuing Obligation. These Interrogatories are continuing in nature. Defendant must seasonably supplement responses as required by R.I. R. Civ. P. 26(e) whenever additional or corrective information becomes available.

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below. These definitions apply throughout regardless of capitalization:

A. "Action" means the above-captioned lawsuit pending in the Rhode Island Superior Court.

B. "Communication" means any oral, written, or electronic transmission of information, including but not limited to letters, memoranda, emails, text messages, instant messages, social media posts or messages, voicemails, telephone calls, facsimiles, video conferences, meetings, and face-to-face conversations.

C. "Concerning," "Relating to," or "Regarding" means directly or indirectly mentioning, referencing, describing, reflecting, evidencing, constituting, or in any way pertaining to the identified subject matter.

D. "Document" is defined as in R.I. R. Civ. P. 34(a) and includes without limitation all writings, drawings, graphs, charts, photographs, sound recordings, images, electronically stored information ("ESI"), drafts, metadata, and all copies that differ in any respect from the original.

E. "Identify" or "Identification" means:

• (i) For a natural person: state full legal name, all known aliases, present or last-known residential address, telephone number, email address, current employer, job title, and relationship to any party in this Action;
• (ii) For a business entity: state the full legal name, jurisdiction of formation, principal place of business address, and the name, title, and contact information of the individual most knowledgeable about the subject matter;
• (iii) For a document: state the title or description, date, author(s), recipient(s), type (e.g., email, contract, report), Bates number (if any), and present custodian or location.

F. "Incident" means the events, occurrences, transactions, or omissions giving rise to this litigation as described in the Complaint: [________________________________] (brief description).

G. "Person" means any natural person, corporation, limited liability company, partnership, joint venture, association, governmental entity, or any other legal or business entity.

H. "You," "Your," or "Defendant" means [________________________________], including all officers, directors, employees, agents, attorneys, subsidiaries, affiliates, and any other Person acting or purporting to act on behalf of Defendant.

III. INSTRUCTIONS

1. Answering Under Oath. Each Interrogatory shall be answered separately and fully in writing under oath, signed by the answering party, and signed by counsel in accordance with R.I. R. Civ. P. 26(g). See R.I. R. Civ. P. 33(a), (b).

2. Form of Answers. Each answer must restate the full text of the corresponding Interrogatory immediately before the response. Answers must be complete, responsive, and not evasive.

3. Objections. State with specificity the grounds for each objection. An objection to part of an Interrogatory does not excuse answering the remainder. Boilerplate or generalized objections are not permitted.

4. Privilege Log. If information is withheld on a claim of attorney-client privilege, work-product protection, or any other privilege, set forth a privilege log that complies with R.I. R. Civ. P. 26(b)(5), identifying the nature of the information sufficient to enable Plaintiff to assess the claim.

5. Supplementation. Defendant must seasonably supplement responses under R.I. R. Civ. P. 26(e). This duty extends to identification of persons having knowledge, expert witnesses, and corrections of any incomplete or incorrect answers.

6. Option to Produce Business Records. Where the answer may be derived or ascertained from business records and the burden of derivation is substantially the same for either party, Defendant may specify the records and afford Plaintiff a reasonable opportunity to examine and copy them. See R.I. R. Civ. P. 33(c).

7. Rules of Construction. The singular includes the plural and vice versa. All genders include each other. The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary. "Including" means "including but not limited to."

8. Time Period. Unless otherwise specified, each Interrogatory covers the period from [__/__/____] through the date of Defendant's response.

9. Computation of Time. Time periods are computed in accordance with R.I. R. Civ. P. 6. If service is by mail, add three (3) days to the response period.

IV. GENERAL INTERROGATORIES

INTERROGATORY NO. 1: Persons Assisting in Preparation

Identify every Person who participated in preparing the answers to these Interrogatories, specifying the subject matter of each Person's contribution.

INTERROGATORY NO. 2: Fact Witnesses

Identify all Persons whom You believe have knowledge of any facts relevant to this Action and provide a brief summary of the knowledge each such Person possesses.

INTERROGATORY NO. 3: Description of Incident

Describe in detail the Incident, including date, time, location, sequence of events, all Persons present or involved, all actions taken, and all conditions or circumstances You believe are relevant.

INTERROGATORY NO. 4: Factual Basis of Defenses

State in detail the factual basis for each denial and each affirmative defense asserted in Your pleadings, identifying all Documents and witnesses supporting each.

INTERROGATORY NO. 5: Insurance Coverage

Identify all insurance agreements under which any Person carrying on an insurance business may be liable to satisfy part or all of a judgment in this Action or to indemnify or reimburse Defendant for payments made to satisfy the judgment. For each, state: (a) the insurer's name and address; (b) the policy number; (c) the type of coverage; (d) the effective dates; (e) the limits of liability; (f) any applicable deductibles; and (g) any reservation-of-rights positions taken.

INTERROGATORY NO. 6: Expert Witnesses

State the full name, address, and telephone number of each expert witness You intend to call at trial. For each, summarize: (a) the substance of the opinions to be offered; (b) the basis for each opinion; (c) the qualifications of the expert; and (d) compensation arrangements.

INTERROGATORY NO. 7: Damages

Itemize and compute all damages You claim to have incurred or will incur (if any counterclaim or cross-claim is asserted), including the method of computation and identification of all supporting Documents.

INTERROGATORY NO. 8: Third-Party Fault

State whether You contend that any other Person or entity is responsible, in whole or in part, for the damages claimed by Plaintiff. If so, identify each such Person and describe the factual and legal basis for that contention.

INTERROGATORY NO. 9: Documents Relating to Incident

Identify and describe all Documents that relate to the Incident, including but not limited to photographs, video footage, correspondence, contracts, maintenance or inspection records, and incident reports.

INTERROGATORY NO. 10: Investigations

Describe any investigations conducted by or on behalf of Defendant regarding the Incident, including: (a) the identity of the investigator(s); (b) the dates of investigation; (c) the scope; and (d) the conclusions reached (to the extent not privileged).

INTERROGATORY NO. 11: Communications with Plaintiff

For each Communication between Defendant and Plaintiff relating to the claims or defenses in this Action, identify: (a) the date; (b) the participants; (c) the medium; and (d) the substance.

INTERROGATORY NO. 12: Statements

Identify any statements (written, recorded, or oral) made by Plaintiff, Defendant, or any witness concerning the Incident. For each, provide: (a) the date; (b) the identity of the declarant; (c) the Person to whom it was made; (d) the substance; and (e) the present custodian.

INTERROGATORY NO. 13: Mitigation of Damages

State all facts supporting any contention that Plaintiff failed to mitigate damages, including identification of all Documents and witnesses supporting such contention.

INTERROGATORY NO. 14: Safety Policies and Procedures

Describe with particularity all safety policies, procedures, or training applicable at the time of the Incident, and identify all Documents evidencing same.

INTERROGATORY NO. 15: Prior Litigation

Identify each lawsuit, claim, or administrative proceeding within the last ten (10) years in which Defendant has been named as a party relating to substantially similar facts or allegations. For each, state: (a) the case name; (b) the docket number; (c) the court or agency; (d) the nature of the claim; and (e) the outcome.

INTERROGATORY NO. 16: Remedial Measures

State whether any repairs, modifications, or corrective actions were undertaken following the Incident. If so, describe each such action, the date performed, and the Person(s) responsible.

INTERROGATORY NO. 17: Photographs and Media

Identify all photographs, videos, audio recordings, or other media relating to the Incident, any party, or any issue in this Action. For each, state: (a) the date created; (b) the creator or source; (c) the subject matter; and (d) the present custodian.

INTERROGATORY NO. 18: Document Preservation

Describe all efforts undertaken to preserve Documents and ESI relevant to this Action, including: (a) the date of any litigation hold; (b) the Person(s) responsible for oversight; (c) the scope; and (d) whether any potentially responsive information has been lost, destroyed, or deleted.

INTERROGATORY NO. 19: Contested Damages

State all facts upon which You rely to contest Plaintiff's claimed damages, including the amount of damages You admit are owed (if any), and identify all supporting Documents and witnesses.

INTERROGATORY NO. 20: Liability Denial

If You deny liability in whole or in part, state the precise legal and factual bases for such denial and identify all Documents and witnesses supporting Your position.

V. CASE-SPECIFIC INTERROGATORIES

The following blank interrogatories are provided for attorney customization. Ensure the total number of interrogatories, including all parts and sub-parts, does not exceed thirty (30) without leave of court under R.I. R. Civ. P. 33(a).

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

INTERROGATORY NO. [____]:

[________________________________]

VI. VERIFICATION / OATH

Instructions to Responding Party: Rhode Island Rule of Civil Procedure 33(a) requires that interrogatory answers be made under oath. The answering party must sign the verification, and counsel must also sign pursuant to R.I. R. Civ. P. 26(g).

STATE OF RHODE ISLAND

COUNTY OF [________________________________]

I, [________________________________], being duly sworn, depose and say that I am the ☐ individual party / ☐ [________________________________] (title/position) of [________________________________] (entity name); that I have read the foregoing Answers to Interrogatories and know the contents thereof; and that the answers are true, correct, and complete to the best of my knowledge, information, and belief.

Date: [__/__/____]

Signature: [________________________________]

Printed Name: [________________________________]

Title/Position (if entity): [________________________________]

SUBSCRIBED AND SWORN TO before me this [____] day of [________________________________], 20[____].

Notary Public: [________________________________]

My Commission Expires: [__/__/____]

Attorney Signature (R.I. R. Civ. P. 26(g)):

Signature: [________________________________]

[________________________________], Esq.
Rhode Island Bar No. [________________________________]
[________________________________] (Firm)
[________________________________] (Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)

VII. CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], a true and correct copy of the foregoing Plaintiff's First Set of Interrogatories to Defendant was served upon counsel of record via the method(s) indicated below, in accordance with R.I. R. Civ. P. 5:

Method of Service:

☐ Rhode Island E-Filing / Electronic Service

☐ United States First-Class Mail, postage prepaid

☐ Hand Delivery

☐ Email (by agreement of the parties)

☐ Certified Mail, Return Receipt Requested

☐ Other: [________________________________]

Served Upon:

Signature: [________________________________]

[________________________________], Esq.
Rhode Island Bar No. [________________________________]
[________________________________] (Firm)
[________________________________] (Address)
[________________________________] (City, State, ZIP)
[________________________________] (Telephone)
[________________________________] (Email)
Attorney for Plaintiff

VIII. PRACTICE NOTES

1. Interrogatory Limit. R.I. R. Civ. P. 33(a) limits the total number of interrogatories to thirty (30), including all parts and sub-parts, without leave of court. Draft carefully to stay within this cap while obtaining maximum useful information.

2. Response Deadline. The standard response deadline is thirty (30) days after service. If service is by mail, add three (3) days under R.I. R. Civ. P. 6(e). Calendar the deadline immediately upon service.

3. Oath Requirement. Answers must be made under oath by the responding party, not merely signed by counsel. For entity parties, an authorized officer or agent must sign under oath. Ensure the verification includes a notarized oath or equivalent.

4. Superior Court vs. District Court. This template is designed for Rhode Island Superior Court. The District Court has its own set of rules. Confirm the appropriate court and rules before using this template.

5. Default and Remedies. Failure to serve timely, complete, and verified responses may subject Defendant to sanctions under R.I. R. Civ. P. 37, including orders compelling discovery, cost-shifting, adverse inferences, or default judgment.

6. Meet and Confer. Before filing any motion to compel, counsel should confer or attempt to confer in good faith with opposing counsel to resolve the dispute without court intervention. Check for any local practice requirements or standing orders.

7. Protective Orders. If interrogatories seek trade secrets, confidential business information, or sensitive personal data, consider whether a protective order under R.I. R. Civ. P. 26(c) is appropriate before serving.

8. Coordinating Discovery. Consider serving interrogatories in conjunction with requests for production (R.I. R. Civ. P. 34) and requests for admission (R.I. R. Civ. P. 36) to maximize discovery within the thirty-interrogatory limit.

9. Local Practice. Review any local discovery rules, standing orders, or judge-specific requirements. Rhode Island is a small jurisdiction; familiarity with local practice and judicial preferences is important.

10. Professional Conduct. Ensure compliance with the Rhode Island Rules of Professional Conduct, including Rule 1.1 (competence), Rule 3.4 (fairness to opposing party), and Rule 3.1 (meritorious claims and contentions) when drafting and serving discovery.

IX. SOURCES AND REFERENCES

• Rhode Island Superior Court Rules of Civil Procedure, Rules 5, 6, 26, 26(b)(5), 26(e), 26(g), 29, 33, 34, 36, 37
• Rhode Island Superior Court Rules of Civil Procedure (full text): https://www.courts.ri.gov/Courts/superiorcourt/Documents/SuperiorCourtRulesOfCivilProcedure.pdf
• Rhode Island Judiciary, Superior Court Rules: https://www.courts.ri.gov/Legal-Resources/Pages/Superior-Court-Rules.aspx
• Rhode Island Rules of Professional Conduct
• Rhode Island Bar Association: https://www.ribar.com