[COURT NAME]

[JUDICIAL DISTRICT]

[COUNTY], TENNESSEE

[PLAINTIFF NAME],
  Plaintiff,

v.

[DEFENDANT NAME],
  Defendant.

Case No. [__]

FIRST SET OF INTERROGATORIES FROM PLAINTIFF TO DEFENDANT

(Pursuant to Tenn. R. Civ. P. 26 & 33)

[// GUIDANCE: Tailor the substance of each Interrogatory to fit the pleadings and theories in your case. Confirm that all Interrogatories—including discrete sub-parts—total no more than thirty (30) absent court order, per Tenn. R. Civ. P. 33.]

I. PRELIMINARY STATEMENT

Plaintiff [PLAINTIFF NAME] (“Plaintiff”), by counsel and pursuant to Rules 26 and 33 of the Tennessee Rules of Civil Procedure, hereby propounds the following Interrogatories to Defendant [DEFENDANT NAME] (“Defendant”). Defendant shall serve sworn, written answers within thirty (30) days of service hereof, except that a Defendant first served with these Interrogatories together with the summons and complaint shall serve answers within forty-five (45) days. Answers shall be served upon the undersigned counsel at the address shown below.

II. DEFINITIONS & INSTRUCTIONS

For purposes of these Interrogatories:

1. “Document” and “Electronically Stored Information” (“ESI”) have the broadest meanings permitted under Tenn. R. Civ. P. 34, and include all drafts and non-identical copies.
2. “Identify” or “state the identity of” means:
   a. For a natural person: full name, present or last-known address, telephone number, and employer/position at the relevant time;
   b. For a business entity: full legal name, jurisdiction of formation, principal place of business, and a contact person;
   c. For a document/ESI: (i) nature (e.g., letter, e-mail), (ii) date, (iii) author(s) and recipient(s), (iv) subject line or description, (v) present custodian/location.
3. “Incident” refers to the transaction(s), occurrence(s), or event(s) alleged in Plaintiff’s Complaint filed on [Filing Date].
4. “You,” “Your,” and “Defendant” mean [DEFENDANT NAME], all present and former agents, employees, representatives, attorneys, and anyone acting or purporting to act on its behalf.

General Instructions:

A. Each Interrogatory must be answered separately and fully in writing under oath.
B. If any Interrogatory is objected to, state the specific ground(s) and answer the portion not objected to. Boilerplate or blanket objections are improper.
C. If You withhold information based on any privilege or protection, expressly identify the privilege claimed and provide a privilege log sufficient to allow assessment of the claim, consistent with Tenn. R. Civ. P. 26.
D. These Interrogatories are continuing. Promptly supplement or correct Your answers in accordance with Tenn. R. Civ. P. 26(e).
E. Unless otherwise indicated, the relevant period is from [RELEVANT START DATE] to the present.

[// GUIDANCE: Insert any agreed-upon ESI protocols or protective-order references here, if applicable.]

III. INTERROGATORIES

1. Identify every person who prepared, reviewed, or assisted in preparing the answers to these Interrogatories, specifying each person’s role.
2. State in detail the factual basis for each affirmative defense pled in Your Answer.
3. Describe the nature and amount of all damages You contend Plaintiff has sustained, and state the method used to compute each category of damages.
4. Identify all persons known to You who witnessed, were present at, or claim knowledge of the Incident, and state the substance of the knowledge held by each.
5. Identify all Documents or ESI that relate to the Incident, including photographs, video, audio recordings, correspondence, and internal memoranda.
6. State the name and address of every expert witness You expect to call at trial and, for each, provide the subject matter of expected testimony and a summary of opinions.
7. Describe in detail each insurance agreement under which any person or entity may be liable to satisfy part or all of a judgment in this action or to indemnify or reimburse payments made to satisfy a judgment.
8. If You contend Plaintiff failed to mitigate damages, set forth each fact supporting that contention.
9. Identify all communications (oral or written) between You and Plaintiff concerning the matters alleged in the Complaint, including date, method (e-mail, phone, in-person), participants, and substance.
10. State every policy, procedure, or guideline in effect at the time of the Incident that is relevant to the claims or defenses in this action, and identify the custodian of each written policy.
11. Describe any investigation conducted by or on behalf of Defendant concerning the Incident, including the date commenced, persons involved, and Documents generated.
12. Identify each prior lawsuit, claim, or administrative proceeding within the past ten (10) years arising from similar allegations against Defendant, stating case style, docket number, court/agency, and disposition.
13. If You contend that any third party is wholly or partly responsible for the damages alleged, identify such person or entity and describe the factual and legal basis for that contention.
14. State whether You have spoliated, lost, or destroyed any Documents or ESI potentially relevant to this action, and if so, describe the circumstances and any efforts undertaken to recover the information.
15. Set forth all facts upon which You rely to dispute Plaintiff’s computation of damages.

[// GUIDANCE: Delete, revise, or add Interrogatories as needed. Ensure compliance with the 30-interrogatory cap.]

IV. VERIFICATION

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

[Name]
[Title]
Date: ____

STATE OF __
COUNTY OF __

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

Notary Public
My Commission Expires: ____

V. CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Interrogatories was served via [METHOD OF SERVICE] upon:

[Opposing Counsel Name]
[Law Firm]
[Address]
[E-mail]

on this ___ day of _, 20.

[Attorney Name]
Counsel for Plaintiff
[Bar Number]
[Law Firm]
[Address]
[Phone] | [E-mail]

[// GUIDANCE:
1. Calendar the 30-day (or 45-day) response deadline immediately upon service.
2. Reserve Interrogatory “slots” for follow-up discovery if needed.
3. If Defendant objects based on privilege, demand a privilege log that satisfies Tenn. R. Civ. P. 26.
4. Consider pairing these Interrogatories with parallel Requests for Production under Rule 34 to minimize “information-only” responses. ]

© [Year] [Your Firm Name]. All rights reserved.