PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

[// GUIDANCE: Change “Plaintiff” and “Defendant” (and the sequence number) to match your case posture.]

I. CAPTION & INTRODUCTORY INFORMATION

text
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
[COUNTY] COUNTY )
) C/A No.: [_]
[PLAINTIFF NAME], )
)
Plaintiff, )
) PLAINTIFF’S FIRST SET OF
v. ) INTERROGATORIES TO DEFENDANT
) (SCRCP 33)
[DEFENDANT NAME], )
)
Defendant. )
_________ )
Effective Date of Service: [MM/DD/YYYY]
Governing Procedural Law: South Carolina Rules of Civil Procedure (“SCRCP”).

II. PRELIMINARY STATEMENT, DEFINITIONS & INSTRUCTIONS

1. Purpose. These Interrogatories are served pursuant to S.C. R. Civ. P. 33 and are subject to the aggregate limit of fifty (50) interrogatories, including all discrete subparts, unless otherwise ordered by the Court.
2. Duty to Supplement. Answers must be seasonably supplemented in accordance with S.C. R. Civ. P. 26(e).
3. Deadline. Written, verified answers are due within thirty (30) days after service (or forty-five (45) days for a defendant first served with the summons and complaint).
4. Manner of Response.
   a. Restate each Interrogatory immediately before the corresponding answer.
   b. If any Interrogatory is objected to, state the specific grounds and answer the remainder.
5. Privilege Log. Information withheld on the basis of privilege or protection must comply with S.C. R. Civ. P. 26(b)(5)(A).
6. Definitions.
   a. “You,” “Your,” “Defendant,” or “[DEFENDANT NAME]” mean the party to whom these Interrogatories are directed, including all predecessors, successors, parents, subsidiaries, affiliates, officers, directors, employees, agents, and attorneys.
   b. “Document” and “Electronically Stored Information” (“ESI”) have the broadest meaning permitted under SCRCP 26 and 34.
   c. “Identify” when referring to a natural person means to provide full name, present or last-known address and telephone number, and relationship to the litigation; when referring to an entity, provide full legal name, address, and place of incorporation; when referring to a document/ESI, provide date, author, recipient(s), type, title/subject, and Bates range (if known).
   [// GUIDANCE: Add or tailor definitions to suit case specifics—e.g., “Accident,” “Product,” “Confidential Information.”]

III. GENERAL OBJECTIONS [Apply to each Interrogatory]

1. Plaintiff objects to the extent any Interrogatory seeks information protected by the attorney–client privilege, work-product doctrine, or any other applicable privilege or immunity.
2. Plaintiff objects to each Interrogatory that is overly broad, unduly burdensome, vague, ambiguous, or not proportional to the needs of the case.
3. Plaintiff reserves all objections as to admissibility, materiality, relevance, competency, and authenticity of any information produced.
   [// GUIDANCE: Modify or delete boilerplate as appropriate; avoid reflexive, unsupported objections.]

IV. SPECIFIC INTERROGATORIES

Note: The numeration below presumes this is the first set. If additional sets will be served, renumber sequentially and monitor the 50-interrogatory cap (including subparts).

1. Identify every person whom You contend has knowledge of any fact alleged in the pleadings, stating for each such person the subject matter of the knowledge and a summary of the facts known.
2. Describe in detail the factual basis for each affirmative defense asserted in Your answer, including identification of all supporting documents and witnesses.
3. State the exact amount of damages You contend Plaintiff has sustained and describe the method of calculation, including all documents on which You rely.
4. Identify all statements, written or oral, obtained by You or on Your behalf concerning the incident at issue, providing date, participants, and present custodian.
5. For each insurance agreement that may satisfy part or all of any judgment in this action, identify the insurer, policy number, limits, and applicable endorsements.
6. Describe any investigations conducted by You relating to the facts alleged in the Complaint, including the identity of investigators and the scope of each investigation.
7. State whether You contend any third party is wholly or partially at fault, and if so, identify each such person or entity and describe the factual and legal basis.
8. Identify and describe any expert witnesses You expect to call at trial, including the subject of testimony, opinions held, bases therefor, and all reports provided to You.
9. Describe all efforts made to preserve documents and ESI potentially relevant to this litigation, including issuance of any litigation hold notices.
10. Provide the name, title, and contact information of the individual(s) answering these Interrogatories and the information each individual supplied.
    [// GUIDANCE: Insert, delete, or tailor interrogatories to fit the substantive claims (e.g., product liability, employment discrimination, construction defect). Remember that each discrete question or request for multiple facts counts as a separate interrogatory.]

V. VERIFICATION

text
STATE OF SOUTH CAROLINA )
) VERIFICATION
[COUNTY] COUNTY )

I, _______, being duly sworn, state that I am the [TITLE/POSITION] of [DEFENDANT NAME]; that I have read the foregoing Answers to Interrogatories and know the contents thereof; and that the same are true and correct to the best of my knowledge, information, and belief.

[NAME]
[DATE]

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

Notary Public for South Carolina
My commission expires: ____
[// GUIDANCE: SCRCP 33 requires answers under oath signed by the party—not merely counsel. Attach additional signature lines for multiple parties as needed.]

VI. CERTIFICATE OF SERVICE

text
I HEREBY CERTIFY that on this _ day of _, 20__, I served the foregoing PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT by [method of service permitted under SCRCP 5(b)] upon counsel of record at the address(es) indicated below:

[Opposing Counsel Name]
[Firm]
[Address]
[Email (if consented)]

[Attorney Name], Esquire
[SC Bar No. ______]
[Law Firm]
[Address]
[Telephone] | [Email]
Counsel for Plaintiff

PRACTICAL CHECKLIST & RISK-MITIGATION NOTES

[// GUIDANCE: Delete before filing]

• Count each subpart—South Carolina’s 50-interrogatory limit is strictly enforced.
• Build a parallel Request for Production if any interrogatory requests documents (SCRCP 34).
• Where privilege is asserted, prepare a compliant privilege log contemporaneously.
• Consider formatting answers in separate numbered paragraphs to streamline motions to compel.
• If proceeding in the Business Court Pilot Program, confirm any case-specific discovery orders.
• Revisit deadlines when serving along with initial complaint—the 45-day rule is easy to miss.
• For electronically served discovery, confirm consent to e-service under SCRCP 5(b)(1).

END OF DOCUMENT