Rhode Island State Court Discovery Interrogatories

RHODE ISLAND STATE COURT DISCOVERY INTERROGATORIES

STATE OF RHODE ISLAND — SUPERIOR COURT

County / division: [________________________________]

C.A. No.: [________________________________]

[REQUESTING PARTY]'S INTERROGATORIES TO [RESPONDING PARTY]

To: [RESPONDING PARTY AND COUNSEL]

Under R.I. Super. R. Civ. P. 33, [REQUESTING PARTY] serves these interrogatories on [RESPONDING PARTY] concerning [IDENTIFIED SUBJECT MATTER OF ACTION]. Each selected question is limited to nonprivileged matter relevant to the subject matter of this action under Rule 26(b)(1).

Service gate: If the requesting party is the plaintiff and serves interrogatories within 60 days after service of process on the defendant, Rule 33(a) requires leave of court first. The process-service date is [__/__/____]. The order granting leave, if needed, is [DATE AND ORDER / NOT APPLICABLE].

Count gate: Rule 33(b) limits the total across sets to 30 interrogatories unless the court orders otherwise for good cause. [____] were served earlier; [____] are selected below; total [____]. Court order permitting a higher total, if any: [________________________________].

RESPONSE INSTRUCTIONS

1. Rule 33(a) requires each interrogatory to be answered separately and fully in writing under oath by the responding party, or for an entity by an officer or agent with information available to the entity. Each answer must be preceded by the question it answers and signed by the person making it.

2. State reasons for an objection to a particular interrogatory and answer the part that is not objectionable. Rule 33(a) governs written objections and the response period.

3. Rule 33(a) generally requires service of answers and objections within 40 days after service of these interrogatories, subject to a different court-ordered time. Rule 6(d) adds one day to a prescribed period after a paper is served electronically or by mail. Calculated response date for this service: [__/__/____].

4. A privilege or trial-preparation claim must be made expressly and supported by a description sufficient for the other parties to assess it without disclosure of protected information under Rule 26(b)(5).

5. Rule 33(c) requires an amended answer when later information renders an answer incomplete or incorrect, within a reasonable time after the new information is obtained and not later than 30 days before the fixed trial date. Later amendment may be allowed only on motion and the court's terms.

6. A responding party relying on business records under Rule 33(d) must satisfy that rule's substantially equal burden condition, specify the records with enough detail to locate the answer, and afford a reasonable opportunity to examine, audit, or inspect and copy them.

INTERROGATORIES

Select and tailor only questions relevant to the pleaded claims and defenses. Replace broad placeholders with dates, identified actors, and a defined event or transaction.

Interrogatory No. 1. Identify each person with knowledge of [SPECIFIC EVENT OR TRANSACTION] during [DATE RANGE] and state the subject of that person's knowledge.

Interrogatory No. 2. State the sequence of events involving [SPECIFIC EVENT] on [DATE], identifying the acts of [PARTIES OR PERSONS].

Interrogatory No. 3. Identify the factual basis for your denial of Complaint paragraph [____] concerning [SPECIFIC ALLEGATION].

Interrogatory No. 4. Identify the facts supporting your pleaded [NAMED AFFIRMATIVE DEFENSE] to Count [____].

Interrogatory No. 5. Identify the communications between [PERSON A] and [PERSON B] about [SPECIFIC ISSUE] during [DATE RANGE], stating the dates and participants.

Interrogatory No. 6. Identify the records on which you rely to support [SPECIFIC FACTUAL CONTENTION], stating their dates and custodians.

Interrogatory No. 7. State the amount and calculation of [SPECIFIC PAYMENT OR DAMAGES CLAIM] for [DATE RANGE], identifying the underlying records.

Interrogatory No. 8. Identify the persons who inspected or repaired [SPECIFIC PROPERTY OR EQUIPMENT] between [DATES] and state the dates and nature of that work.

Interrogatory No. 9. Describe the notice you received about [SPECIFIC CONDITION OR EVENT] before [DATE], including the source and date of each notice.

Interrogatory No. 10. Identify the insurance agreement under which an insurer may satisfy or reimburse a judgment concerning [SPECIFIC CLAIM], if any, and identify the insurer and agreement.

Interrogatory No. 11. Identify the nonprivileged investigation records concerning [SPECIFIC EVENT] created by [IDENTIFIED UNIT OR PERSON] during [DATE RANGE].

Interrogatory No. 12. State [ONE CASE-SPECIFIC QUESTION ABOUT A FACT OR APPLICATION OF LAW TO FACT, WITH ACTOR, EVENT, AND DATE].

SIGNATURE

Signature of requesting attorney or self-represented party: ________________________________________

Printed name: [________________________________]

Rhode Island Bar number (if attorney): [________________________________]

Address: [________________________________]

Telephone: [________________________________]

Email: [________________________________]

Counsel for: [________________________________]

Date: [__/__/____]

CERTIFICATE OF SERVICE

I certify that on [__/__/____] I served these interrogatories on the following persons by the methods identified:

☐ Served through the Rhode Island Judiciary EFS. The electronically served document is available for viewing or downloading from the EFS.

☐ Served conventionally because this discovery does not lend itself to electronic service or the recipient is not a registered user. The method and proof are identified above.

Signature: ________________________________________

Printed name: [________________________________]

Date: [__/__/____]

SOURCES AND REFERENCES

• Rhode Island Superior Court Rules of Civil Procedure (February 2024): https://www.courts.ri.gov/Courts/superiorcourt/Documents/SuperiorCourtRulesOfCivilProcedure.pdf
• Rhode Island Supreme Court Article X, electronic filing: https://www.courts.ri.gov/Courts/SupremeCourt/Documents/Supreme-Rules-Article10.pdf