[COURT NAME]

[CASE TITLE: e.g., John Doe v. ABC Corporation]

C.A. No. [CASE NUMBER]

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

(Rhode Island Superior Court – Rule 33)

[// GUIDANCE: Replace “Plaintiff/Defendant,” “First,” “ABC Corporation,” etc. as appropriate. If served by a defendant, invert party names and adjust pronouns.]

I. DOCUMENT HEADER

1. Effective Date of Service: [DATE]
2. Propounding Party: [PLAINTIFF NAME] (“Plaintiff”)
3. Responding Party: [DEFENDANT NAME] (“Defendant”)
4. Governing Law & Procedural Rules: Rhode Island Superior Court Rules of Civil Procedure (“R.I. R. Civ. P.”), particularly Rules 26, 33, and 37.
5. Forum: Rhode Island [Superior/District/Family] Court, [County] County.

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below. All definitions are intended to encompass the singular and plural, the present and past tense, and all genders.

“Communication” means any transmission of information, whether oral, written, or electronic, including but not limited to correspondence, email, text message, social-media post, meeting, telephone call, or video conference.

“Document” is defined as in R.I. R. Civ. P. 34(a) and includes without limitation electronically stored information (“ESI”), drafts, metadata, and all copies that differ in any respect from the original.

“Identify” or “Identification” when used with:
a. A natural person – state full name, present or last-known address, telephone number, employer, and job title.
b. A business entity – state full legal name, jurisdiction of formation, principal place of business, and the name, title, and contact information of the individual most knowledgeable about the subject matter.
c. A document – state title, date, author(s), recipient(s), type of document (e.g., email, contract), bates number (if any), and present custodian.

“Incident” means [BRIEF DESCRIPTION OF INCIDENT/TRANSACTION AT ISSUE].

“You,” “Your,” or “Defendant” refers to [DEFENDANT NAME], including all officers, directors, employees, agents, attorneys, subsidiaries, and affiliates.

III. OPERATIVE PROVISIONS (INSTRUCTIONS & RULES)

1. Number Limitations. Pursuant to R.I. R. Civ. P. 33(a), a party may not serve “more than forty (40) interrogatories, including all parts and sub-parts,” without leave of court. This set comprises [NUMBER] interrogatories, inclusive of discrete sub-parts.
2. Response Deadline. Answers and any objections must be served within 40 days after service of these Interrogatories. R.I. R. Civ. P. 33(b)(3).
3. Manner of Answer. 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).
4. Privilege & Work-Product. If any 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. Duty to Supplement. Defendant must seasonably supplement responses under R.I. R. Civ. P. 26(e).
6. Objections. State with specificity the grounds for each objection. An objection to part of an Interrogatory does not excuse answering the remainder.
7. Computation of Time. Time periods are computed in accordance with R.I. R. Civ. P. 6.
8. Continuing Application. These Instructions and Definitions apply to each Interrogatory below.

IV. INTERROGATORIES

[// GUIDANCE: Tailor, delete, or add Interrogatories to fit the case. Maintain numbering to stay within the 40-Interrogatory cap.]

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

2. State in detail the factual basis for each denial and each affirmative defense asserted in your pleadings.

3. Describe the Incident, including date, time, location, sequence of events, and the identity of all persons present or involved.

4. 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.

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

6. State the full name, address, and telephone number of each expert witness you intend to call at trial and, for each, summarize the substance of the opinions to be offered and the basis therefor.

7. Itemize and compute all damages you claim to have incurred or will incur, including the method of computation and identification of all supporting Documents.

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

9. Identify all insurance agreements under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment that may be entered in the action or to indemnify or reimburse Defendant for payments made to satisfy the judgment.

10. Describe any investigations conducted by or on behalf of Defendant regarding the Incident, including the identity of the investigator(s), dates of investigation, and conclusions reached.

11. For each Communication between Defendant and Plaintiff relating to the claims or defenses in this action, identify the date, participants, medium, and substance of the Communication.

12. Identify any statements (written, recorded, or oral) made by Plaintiff, Defendant, or any witness concerning the Incident, and for each, provide the date, the person who made the statement, the person to whom it was made, and the present custodian.

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

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

15. 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, stating the case name, docket number, court or agency, nature of the claim, and outcome.

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

[// GUIDANCE: Remaining numbers intentionally left blank for attorney customization, ensuring room within the 40-interrogatory limit.]

V. REPRESENTATIONS & WARRANTIES (VERIFICATION)

I, [NAME], hereby certify under oath that I am duly authorized to make these answers on behalf of Defendant, that I have read the foregoing Interrogatories and the answers thereto, and that the answers are true and complete to the best of my knowledge, information, and belief.

Date: _____

[NAME]
[Title/Capacity]

State of Rhode Island
County of ______

Subscribed and sworn before me on __ [date] by ______.

Notary Public
My Commission Expires: _____

VI. DEFAULT & REMEDIES NOTICE

Failure to serve timely, complete, and verified responses may subject Defendant to sanctions, including but not limited to orders compelling discovery, cost-shifting, adverse inferences, or default judgment, pursuant to R.I. R. Civ. P. 37.

VII. RISK ALLOCATION

(Not applicable to interrogatories; intentionally omitted.)

VIII. DISPUTE RESOLUTION

Any discovery disputes arising from these Interrogatories shall be resolved by the Rhode Island [Superior/District/Family] Court in accordance with R.I. R. Civ. P. 37 and applicable court orders.

IX. GENERAL PROVISIONS

1. Amendment & Waiver. Nothing herein waives any right to serve additional discovery with leave of court or written stipulation pursuant to R.I. R. Civ. P. 29.
2. Reservation of Rights. Plaintiff reserves all rights to supplement, amend, or seek further relief based on Defendant’s responses.
3. Electronically Stored Information. To the extent an answer refers to ESI, identify the system, file path, and custodian, and preserve such data pursuant to any existing litigation-hold obligations.

X. CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of ____, 20__, a true and correct copy of the foregoing Plaintiff’s First Set of Interrogatories to Defendant was served upon counsel of record via [method of service consistent with R.I. R. Civ. P. 5].

[ATTORNEY NAME] (#_____)
[Law Firm]
[Address]
[Telephone]
[Email]

[// GUIDANCE:
1. Review local discovery rules or standing orders for any judge-specific requirements (e.g., word counts, discovery dispute procedures).
2. Confirm whether the case falls under District Court or Superior Court—the rule numbers differ slightly in District Court.
3. Consider a protective order for confidential information before serving interrogatories that seek trade secrets or personal data.
4. Always run a conflict check and ensure compliance with Rule 1.1 (competence) and Rule 3.4 (fairness to opposing party) of the Rhode Island Rules of Professional Conduct before serving discovery.]