Tennessee State Court Discovery Interrogatories

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT

Tennessee State Court — Civil Action

COURT CAPTION

[________________________________] COURT OF [________________________________] COUNTY, TENNESSEE
[____] JUDICIAL DISTRICT

[________________________________],
Plaintiff,

v. Case No.: [________________________________]

[________________________________],
Defendant.

PRELIMINARY STATEMENT

Plaintiff [________________________________] ("Plaintiff"), by and through undersigned counsel, and pursuant to Rules 26 and 33 of the Tennessee Rules of Civil Procedure, hereby propounds this First Set of Interrogatories to Defendant [________________________________] ("Defendant").

Response Deadline: Defendant shall serve sworn, written answers to each Interrogatory within thirty (30) days after service of these Interrogatories. However, if Defendant was first served with these Interrogatories simultaneously with or as part of the Summons and Complaint, Defendant shall have forty-five (45) days from service of the Summons and Complaint to answer. Tenn. R. Civ. P. 33.01.

Number Limit: These Interrogatories are drafted consistent with applicable local court rules. Many Tennessee trial courts limit interrogatories to 30 per party absent leave of court (e.g., Knox County Local Rule; Davidson County Local Rule). Verify the applicable local rules for the court in which this case is pending.

Answers Must Be Sworn: Each Interrogatory must be answered separately and fully, in writing, under oath, unless objected to in accordance with these Instructions. Tenn. R. Civ. P. 33.01.

Service of Answers: Serve a copy of the answers and objections, if any, upon counsel for Plaintiff at the address shown below. Do not file the original answers with the Court unless ordered to do so.

SECTION I — DEFINITIONS

As used throughout these Interrogatories, the following terms have the meanings set forth below:

1. "You," "Your," and "Defendant" mean [________________________________], and all current and former officers, directors, employees, agents, representatives, attorneys, predecessors, successors, subsidiaries, affiliates, and all other persons or entities acting or purporting to act on Defendant's behalf.

2. "Plaintiff" means [________________________________], and all current and former officers, directors, employees, agents, representatives, and attorneys acting or purporting to act on Plaintiff's behalf.

3. "Document" means any written, typed, printed, recorded, or electronically stored material of any kind, including but not limited to letters, emails, text messages, memoranda, contracts, agreements, invoices, receipts, bank records, reports, photographs, videos, audio recordings, spreadsheets, databases, social media posts, and all drafts and non-identical copies thereof.

4. "Electronically Stored Information" or "ESI" has the broadest meaning permitted under Tenn. R. Civ. P. 34, and includes all digital documents, email, text messages, voicemail, social media, and metadata.

5. "Identify" or "state the identity of" means:
   - For a natural person: full legal name, current or last-known address, telephone number, email address, employer, job title, and relationship to the parties;
   - For a business entity: full legal name, form of organization (corporation, LLC, etc.), state of formation, principal place of business, and name of a contact person with authority to speak on the entity's behalf;
   - For a Document or ESI: (a) nature or type (e.g., email, contract, letter, text message), (b) date created or sent, (c) author(s) and all recipients, (d) subject line, title, or brief description of contents, (e) current custodian and location.

6. "Communication" means any transmission of information, whether oral or written, formal or informal, including in-person conversations, telephone calls, voicemails, text messages, emails, letters, memoranda, and electronic messaging of any kind.

7. "The Incident" or "Subject Incident" refers to the transaction(s), occurrence(s), event(s), or dispute that forms the basis of Plaintiff's Complaint filed in this action on [__/__/____], as more particularly described therein.

8. "Complaint" means Plaintiff's Complaint filed in this action on [__/__/____], as well as any amendments thereto.

9. "Answer" means Defendant's Answer and any amendments thereto.

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

11. "Relating to," "relating," "regarding," "concerning," or "with respect to" mean directly or indirectly mentioning, describing, summarizing, reflecting, constituting, comprising, evidencing, substantiating, refuting, or in any way logically or factually connected with the matter described.

12. "Relevant Period" means the period from [__/__/____] through the present date, unless a specific Interrogatory states otherwise.

SECTION II — INSTRUCTIONS

1. Separate and Full Answers Required. Each Interrogatory must be answered separately and fully in writing under oath. Tenn. R. Civ. P. 33.01. Incomplete answers, general references to documents, or answers that incorporate other materials by reference without explanation are improper.

2. Objections. If Defendant objects to any Interrogatory or any part thereof, state the specific legal ground(s) for the objection in accordance with Tenn. R. Civ. P. 33.01 (as amended effective July 1, 2020, to prohibit vague, generalized, or boilerplate objections). Answer the portion of the Interrogatory to which no objection is made. An objection to part of an Interrogatory does not excuse answering the remainder.

3. Privilege Log. If Defendant withholds any information based on a claim of attorney-client privilege, work-product protection, or any other privilege or protection, state the specific privilege claimed and provide a privilege log consistent with Tenn. R. Civ. P. 26. The log must identify sufficient information to allow Plaintiff to assess the claim without revealing the privileged content.

4. Supplementation Required. These Interrogatories are continuing in nature. Defendant must promptly supplement or correct any answer that is incomplete or inaccurate when additional information becomes known, as required by Tenn. R. Civ. P. 26.05.

5. Scope of Knowledge. Each Interrogatory calls for all information within Defendant's knowledge, possession, custody, or control, including information known to Defendant's attorneys, agents, representatives, employees, consultants, and others acting on Defendant's behalf.

6. Conjunctive and Disjunctive. "And" and "or" are used in both the conjunctive and disjunctive sense to make each Interrogatory inclusive rather than exclusive.

7. Singular / Plural. Words used in the singular include the plural and vice versa, as the context requires.

8. No Limitation by Timing. Unless otherwise specified, each Interrogatory calls for information from the beginning of the Relevant Period through the present date of answering, including any information that postdates the filing of the Complaint but is otherwise responsive.

9. Sanctions for Non-Compliance. Failure to comply with these Interrogatories as required by the Tennessee Rules of Civil Procedure may subject Defendant to sanctions under Tenn. R. Civ. P. 37, including striking of pleadings, entry of default, dismissal, or contempt.

SECTION III — INTERROGATORIES

PART A — PARTY IDENTIFICATION AND BACKGROUND

Interrogatory No. 1 — Identity of Persons Preparing Answers

Identify every person who prepared, reviewed, or assisted in any way in preparing the answers to these Interrogatories, and for each person state: (a) full name; (b) title or position; (c) employer; (d) the specific Interrogatories for which the person provided information; and (e) the nature and extent of the person's involvement in preparing the answers.

Interrogatory No. 2 — Defendant's Background Information

State the following information about Defendant:

(a) If Defendant is an individual: full legal name, current address, date of birth, Social Security Number (last four digits only, if required), occupation, and employer at the time of the Incident and currently;

(b) If Defendant is a business entity: full legal name; form of organization (corporation, LLC, partnership, etc.); state of formation; date of formation; principal place of business; registered agent for service of process; and names and titles of all persons with authority to act on Defendant's behalf in connection with the Incident.

Interrogatory No. 3 — Prior Litigation History

Identify all lawsuits, arbitrations, administrative proceedings, or regulatory actions, within the past ten (10) years, to which Defendant was a party (as plaintiff, defendant, respondent, or otherwise), that involve claims similar to or related to those at issue in this action. For each, state: (a) full case name and docket number; (b) court, arbitration forum, or administrative body; (c) date filed; (d) nature of the claims; (e) final disposition; and (f) whether any judgment, settlement, or award was entered against Defendant.

PART B — FACTS OF THE INCIDENT AND DISPUTED EVENTS

Interrogatory No. 4 — Description of the Incident

Describe in full detail the events that constitute or relate to the Subject Incident, including: (a) the date, time, and location of each relevant event; (b) the names and roles of all persons present or involved; (c) the sequence of events as Defendant understands them; and (d) any physical conditions, contractual obligations, or other circumstances Defendant contends are relevant to the claims or defenses in this action.

Interrogatory No. 5 — Defendant's Contentions

State each material factual contention Defendant intends to assert at trial in support of any defense or counterclaim, including: (a) the specific facts supporting each contention; (b) the identity of any witness who will testify to those facts; and (c) the identity of any Document that supports each contention.

Interrogatory No. 6 — Basis for Affirmative Defenses

For each affirmative defense pleaded in Defendant's Answer, state in detail: (a) the factual basis for the defense; (b) all evidence supporting the defense; (c) the identity of each witness who has knowledge relevant to the defense; and (d) the identity of each Document that supports the defense.

Interrogatory No. 7 — Communications Between the Parties

Identify all Communications between Defendant (or anyone acting on Defendant's behalf) and Plaintiff (or anyone acting on Plaintiff's behalf) concerning the Subject Incident, the contract or relationship at issue, or the claims and defenses in this action. For each Communication, state: (a) the date; (b) the method (in-person, telephone, email, text, letter, etc.); (c) the participants; (d) a summary of the substance; and (e) whether any Document memorializes the Communication.

Interrogatory No. 8 — Third-Party Fault or Responsibility

If Defendant contends that any person or entity other than Defendant is wholly or partially responsible for the damages alleged by Plaintiff, identify each such person or entity and describe: (a) the factual basis for that contention; (b) the legal theory or theories under which the third party is responsible; and (c) any Documents or witnesses supporting that contention.

PART C — WITNESSES

Interrogatory No. 9 — Fact Witnesses

Identify all persons (other than experts) whom Defendant expects to call as witnesses at trial or who have knowledge of any facts relevant to the claims or defenses in this action. For each person, state: (a) full name, current address, and telephone number; (b) employer and job title; (c) relationship to Defendant; and (d) a summary of the facts within that person's knowledge.

Interrogatory No. 10 — Eyewitnesses and Persons Present

Identify all persons who were present at, observed, or claim any knowledge of the Subject Incident. For each person, state: (a) full name, current address, and telephone number; (b) what the person witnessed or observed; and (c) whether the person has given any statement, affidavit, or deposition in connection with this matter.

Interrogatory No. 11 — Statements Obtained

State whether Defendant, or anyone acting on Defendant's behalf, has obtained any written, recorded, or signed statement from any person (other than attorneys) concerning the Subject Incident, this lawsuit, or Plaintiff's claims. If so, for each statement identify: (a) the person who gave the statement; (b) the date obtained; (c) the form of the statement (written, audio-recorded, video-recorded, etc.); and (d) the current custodian.

PART D — DOCUMENTS AND ELECTRONICALLY STORED INFORMATION

Interrogatory No. 12 — Documents Relating to the Incident

Identify all Documents and ESI in Defendant's possession, custody, or control that relate to the Subject Incident, the claims or defenses in this action, or Plaintiff's damages. For each Document or category of Documents, identify: (a) the type of Document; (b) the date; (c) the author and recipients; (d) a general description of the contents; and (e) the current custodian and location.

Interrogatory No. 13 — Contracts and Agreements

Identify all contracts, agreements, written understandings, or arrangements between Plaintiff and Defendant (or any predecessor or successor) that relate to the Subject Incident or the claims in this action. For each, state: (a) the date; (b) the parties; (c) the subject matter; (d) whether the agreement was oral or written; and (e) the current custodian of any written agreement.

Interrogatory No. 14 — Document Retention and Preservation

Describe Defendant's document retention policies in effect during the Relevant Period, including any litigation hold or preservation notice issued in connection with this action. If any Documents or ESI potentially relevant to this action have been destroyed, deleted, lost, or made inaccessible since the occurrence of the Subject Incident or the commencement of this lawsuit, describe: (a) the nature of the Documents or ESI; (b) when they were destroyed or lost; (c) the reason for destruction or loss; and (d) any efforts to recover or reconstruct the information.

PART E — DAMAGES

Interrogatory No. 15 — Plaintiff's Alleged Damages

Describe in detail each category of damages Defendant contends Plaintiff has suffered or is entitled to recover, including: (a) the nature of each category; (b) Defendant's position as to the amount of each category; (c) the method of calculation; and (d) all facts and Documents upon which Defendant relies in disputing or supporting each category of damages claimed.

Interrogatory No. 16 — Mitigation of Damages

If Defendant contends that Plaintiff failed to mitigate any damages, state: (a) each specific action or inaction by Plaintiff that Defendant contends constituted a failure to mitigate; (b) the steps Defendant contends Plaintiff should have taken; (c) the estimated amount of damages that could have been avoided; and (d) the identity of all witnesses and Documents supporting this contention.

Interrogatory No. 17 — Offset or Credit

If Defendant contends that any offset, credit, payment, or reduction applies to reduce any damages Plaintiff may recover, state: (a) the nature and amount of each offset or credit; (b) the factual and legal basis for the offset; and (c) identify all Documents and witnesses supporting each claimed offset or credit.

Interrogatory No. 18 — Defendant's Damages (If Any Counterclaim)

If Defendant has asserted or intends to assert a counterclaim, describe in detail: (a) each category of damages sought by Defendant; (b) the amount sought for each category; (c) the method of calculating each category; and (d) identify all Documents and witnesses supporting Defendant's damages calculation.

PART F — INSURANCE

Interrogatory No. 19 — Insurance Coverage

Identify each and every insurance policy, agreement, or arrangement under which any person or entity may be liable to satisfy part or all of a judgment entered in this action, or to indemnify or reimburse Defendant for payments made to satisfy a judgment. For each policy, state: (a) the name and address of the insurer; (b) the policy number; (c) the type of coverage; (d) the policy period; (e) the applicable coverage limits; (f) any deductible amounts; and (g) whether any reservation of rights has been issued.

Interrogatory No. 20 — Claims Made to Insurance

State whether any insurance claim, notice of claim, or tender of defense has been made in connection with the Subject Incident or this lawsuit. If so, describe: (a) the date of the claim or notice; (b) the insurer to whom it was submitted; (c) the policy under which the claim was made; (d) the current status of the claim; and (e) whether coverage was accepted, denied, or is disputed.

PART G — EXPERT WITNESSES

Interrogatory No. 21 — Expert Witnesses

Identify each expert witness Defendant expects to call at trial or whose opinion Defendant may offer into evidence. For each expert, state: (a) full name, address, telephone number, and email; (b) field of expertise; (c) current employer and title; (d) a summary of the subject matter of expected testimony; (e) a summary of the opinions the expert is expected to express; (f) the basis and reasons for each opinion; (g) the facts and data upon which each opinion is based; and (h) a description of all Documents, reports, or materials the expert has prepared, reviewed, or relied upon in connection with this case.

Interrogatory No. 22 — Expert Qualifications and Prior Testimony

For each expert witness identified in response to Interrogatory No. 21, state: (a) the expert's educational background, degrees, certifications, and licenses; (b) whether the expert has testified as an expert in any state or federal court or arbitration proceeding in the past five (5) years; and (c) the case name, docket number, court, and subject matter of each such prior testimony.

PART H — INVESTIGATIONS AND PRIOR INCIDENTS

Interrogatory No. 23 — Investigations

Describe any investigation conducted by or on behalf of Defendant into the Subject Incident, including: (a) the date the investigation was commenced; (b) the identity of all persons who conducted or participated in the investigation; (c) the scope and findings of the investigation; and (d) the identity of all Documents generated in connection with the investigation.

Interrogatory No. 24 — Prior Similar Incidents or Complaints

Identify any prior incident, complaint, claim, grievance, or notice, within the five (5) years preceding the Subject Incident, arising from circumstances substantially similar to those alleged by Plaintiff in this action. For each prior incident, state: (a) the date; (b) the nature of the incident; (c) the identity of the complaining party; (d) any resulting action taken by Defendant; and (e) the final disposition.

PART I — POLICIES, PROCEDURES, AND OPERATIONS

Interrogatory No. 25 — Applicable Policies and Procedures

Identify each policy, procedure, rule, guideline, protocol, or standard (written or unwritten) in effect at the time of the Subject Incident that is relevant to the claims or defenses in this action. For each policy or procedure, state: (a) its title or description; (b) the effective date; (c) the purpose; (d) whether it was in written form; and (e) the identity of the current custodian of any written version.

SECTION IV — VERIFICATION OF ANSWERS

The party answering these Interrogatories must complete the following verification under oath.

STATE OF TENNESSEE

COUNTY OF [________________________________]

I, [________________________________], being first duly sworn, state that I am [________________________________] [state title or position if answering on behalf of an entity] of/for Defendant [________________________________]; that I have read the foregoing Answers to Plaintiff's First Set of Interrogatories; that I have personal knowledge of the matters stated therein, or have gathered the information from persons and records within Defendant's knowledge, possession, and control; and that the answers are true and correct to the best of my knowledge, information, and belief.

Signature: ________________________________________

Printed Name: [________________________________]

Title (if on behalf of entity): [________________________________]

Date: [__/__/____]

Subscribed and sworn to before me this [____] day of [________________________________], 20[____].

________________________________________
Notary Public, State of Tennessee
My Commission Expires: [__/__/____]

SECTION V — OBJECTION GUIDELINES

Note for Defendant's Counsel — Remove before filing or serving.

Under the 2020 amendment to Tenn. R. Civ. P. 33.01, the following practices are improper and subject to sanctions:

☐ General, blanket, or boilerplate objections (e.g., "overly broad and unduly burdensome" without specific factual support)

☐ Objecting to an entire Interrogatory when only part is objectionable, without answering the unobjectionable portion

☐ Failing to state specific grounds for objections with particularity

☐ Using objections as a means to delay or avoid providing responsive information

Proper objection format (example):

"Defendant objects to Interrogatory No. [X] on the grounds that [specific legal basis, e.g., 'the information sought is protected by attorney-client privilege as it reflects confidential legal advice from Defendant's counsel']. Subject to and without waiving this objection, Defendant responds as follows: [response to non-objectionable portions]."

SECTION VI — CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of Plaintiff's First Set of Interrogatories to Defendant was served upon counsel for Defendant as follows:

Defendant's Counsel: [________________________________]

Law Firm: [________________________________]

Address: [________________________________]

Email: [________________________________]

Method of Service:

☐ Hand delivery

☐ U.S. First-Class Mail, postage prepaid

☐ Certified Mail, Return Receipt Requested

☐ Electronic mail (with consent)

☐ Tennessee e-Courts electronic service

☐ Other: [________________________________]

Date of Service: [__/__/____]

Signature: ________________________________________

Printed Name: [________________________________]

Tennessee Bar No.: [________________________________]

Counsel for Plaintiff

Law Firm: [________________________________]

Address: [________________________________]

Phone: [________________________________]

Email: [________________________________]

TENNESSEE DISCOVERY QUICK REFERENCE

(For reference only — remove before serving)

Key Deadlines (Tenn. R. Civ. P. 33.01)

Interrogatory Limits by Jurisdiction (Verify Locally)

Tennessee Statutes of Limitations (T.C.A. §§ 28-3-101 et seq.)

Common Privilege Bases in Tennessee

SOURCES AND REFERENCES

• Tennessee Rules of Civil Procedure — Rule 33 (Interrogatories): https://www.tncourts.gov/rules/rules-civil-procedure/3301
• Tennessee Rules of Civil Procedure — Rule 26 (General Provisions): https://www.tncourts.gov/rules/rules-civil-procedure
• Tennessee Administrative Office of the Courts: https://www.tncourts.gov/
• T.C.A. §§ 28-3-101 through 28-3-116 — Statutes of Limitations: https://law.justia.com/codes/tennessee/title-28/chapter-3/
• T.C.A. § 47-2-725 — UCC Sale of Goods Limitation: https://law.justia.com/codes/tennessee/title-47/chapter-2/section-47-2-725/
• Knox County Local Rules of Practice: https://www.knoxcounty.org/chancery/local_rules.php
• Davidson County Circuit Court Local Rules: https://circuitclerk.nashville.gov/wp-content/uploads/Local-Rules_Circuit_FINAL_070119.pdf
• Frost Brown Todd — Tennessee vs. Federal Procedure Comparison: https://frostbrowntodd.com/procedural-differences-between-tennessee-state-and-federal-court/

This template is provided for informational purposes only and does not constitute legal advice. Consult a licensed attorney before use.