State Court Discovery - Interrogatories - Utah
[PROPONDING PARTY]’S [FIRST/SECOND] SET OF INTERROGATORIES TO [ANSWERING PARTY]
Attorney Review and Discovery-Control Sheet
Complete this sheet before serving the interrogatories. Remove it from the service copy unless counsel directs otherwise.
| Control item | Verified entry |
|---|---|
| Court and judicial district | [________________________________________] |
| Case number and assigned judge | [________________________________________] |
| Practice-area discovery rule, if any | [________________________________________] |
| Scheduling, case-management, or standing order | [________________________________________] |
| Stipulation affecting discovery | [________________________________________] |
| Date propounding side completed required initial disclosures | [__/__/____] |
| Applicable discovery tier | ☐ Tier 1 ☐ Tier 2 ☐ Tier 3 ☐ Tier 4 |
| Interrogatories previously used by this side, including discrete subparts | [____] |
| Interrogatories available under the controlling limit | [____] |
| Standard fact-discovery closing date | [__/__/____] |
| Permission for extraordinary discovery, if needed | [________________________________________] |
| Confidentiality or protective order | [________________________________________] |
| Current service method and recipient list verified | ☐ |
Current Rule 26 Standard Limits
Utah Rule of Civil Procedure 26(c)(5) sets standard fact-discovery limits per side, with plaintiffs, defendants, and third-party defendants counted collectively within their respective sides.
| Tier | Claim or action category | Rule 33 interrogatories, including all discrete subparts |
|---|---|---|
| 1 | $50,000 or less | 0 |
| 2 | More than $50,000 and less than $300,000, or nonmonetary relief without an accompanying claim of $300,000 or more | 10 |
| 3 | $300,000 or more | 20 |
| 4 | Domestic relations action | 10 |
Do not use this form in Tier 1 as standard discovery. If the proposed set exceeds the controlling standard limit, confirm a valid stipulation, court authorization, or expanded discovery schedule before service.
Caption
| Party | Role |
|---|---|
| [PLAINTIFF NAME(S)], | Plaintiff(s) |
| v. | |
| [DEFENDANT NAME(S)], | Defendant(s) |
IN THE [____] JUDICIAL DISTRICT COURT IN AND FOR [____________] COUNTY, STATE OF UTAH
Case No.: [____________________]
Judge: [____________________]
Interrogatories
Under Utah Rules of Civil Procedure 26 and 33, [PROPONDING PARTY] serves the following interrogatories on [ANSWERING PARTY].
The responding party must restate each interrogatory before responding; answer each interrogatory separately and fully in writing under oath or affirmation unless objected to; state the reasons for each objection; and answer any part that is not objectionable. The written response is due within 28 days after service unless a controlling rule, stipulation, or court order changes that period.
Drafting Instructions
For every proposed interrogatory:
- Link it to a pleaded claim or defense.
- Confirm that it is relevant and proportional under Rule 26(b).
- Count every discrete subpart against the applicable Rule 26(c)(5) limit.
- Remove information already supplied by disclosures or a less burdensome source unless the request remains necessary and proportional.
- Separate a request for identification from a Rule 34 request to produce documents.
- Avoid defining “you” to include counsel or every current and former affiliate without a case-specific basis.
- Do not request privileged material. Tailor any request involving experts, medical information, confidential information, or electronically stored information to the controlling rules and orders.
Definitions Selected for This Case
Use only definitions needed for the final questions. Delete unused definitions.
-
“Action” means this lawsuit and the claims and defenses identified in the operative pleadings dated [__/__/____].
-
“Answering Party” means [FULL LEGAL NAME].
-
“Identify,” when used for a person, means state the person’s name and the contact or locating information that counsel has determined is relevant, proportional, and permissible to request: [________________________________________].
-
“Identify,” when used for a communication, event, or record, means provide the case-specific information stated here: [________________________________________].
-
Additional defined term: [TERM] means [________________________________________].
Question Selection Worksheet
| Proposed question | Pleaded claim or defense | Why proportional | Discrete-subpart count | Keep |
|---|---|---|---|---|
| [________________________________] | [________________] | [________________] | [____] | ☐ |
| [________________________________] | [________________] | [________________] | [____] | ☐ |
| [________________________________] | [________________] | [________________] | [____] | ☐ |
| [________________________________] | [________________] | [________________] | [____] | ☐ |
| [________________________________] | [________________] | [________________] | [____] | ☐ |
Optional Question Modules
These are drafting prompts, not a ready-made universal set. Use only a tailored question that passes the worksheet above.
Pleading Basis
INTERROGATORY NO. [____]:
State the material facts on which you base [IDENTIFY SPECIFIC ALLEGATION, DENIAL, CLAIM, OR DEFENSE IN THE OPERATIVE PLEADING].
Persons With Relevant Information
INTERROGATORY NO. [____]:
Identify each person whom you contend has information concerning [IDENTIFY NARROW EVENT OR ISSUE], and state the subject of that information.
Damages or Other Monetary Amount
INTERROGATORY NO. [____]:
State the amount you claim for [IDENTIFY DAMAGES CATEGORY OR OTHER MONETARY ISSUE] and describe the method used to calculate that amount.
Event Chronology
INTERROGATORY NO. [____]:
Describe the events concerning [IDENTIFY NARROW DISPUTED EVENT] from [STARTING EVENT OR DATE] through [ENDING EVENT OR DATE].
Communication
INTERROGATORY NO. [____]:
Identify the communication concerning [IDENTIFY NARROW SUBJECT] that occurred on or about [DATE OR DATE RANGE] between [IDENTIFIED PARTICIPANTS].
Business Records Option
Rule 33(d) permits a responding party to identify business records from which an answer may be found only when the answer may be found by inspection and the burden of finding it is substantially the same for both parties. The records must be identified in enough detail to let the asking party locate and identify them as readily as the answering party, and a reasonable inspection opportunity must be given.
Final Interrogatories for Service
INTERROGATORY NO. 1:
[____________________________________________________________]
[____________________________________________________________]
INTERROGATORY NO. 2:
[____________________________________________________________]
[____________________________________________________________]
INTERROGATORY NO. 3:
[____________________________________________________________]
[____________________________________________________________]
Signature
DATED this [____] day of [________________], [20____].
[LAW FIRM OR PARTY NAME]
By: [________________________________]
[ATTORNEY NAME OR SELF-REPRESENTED PARTY]
Utah Bar No. [____________], if applicable
[ADDRESS]
[TELEPHONE]
[EMAIL]
Attorney for [PROPONDING PARTY], if applicable
Certificate of Service
I certify that on [__/__/____], I served a true and correct copy of [PROPONDING PARTY]’S [FIRST/SECOND] SET OF INTERROGATORIES TO [ANSWERING PARTY] on the following persons by the method verified under the current rules and any controlling order:
| Recipient | Counsel or party | Address or service account | Method |
|---|---|---|---|
| [________________] | [________________] | [________________] | [________________] |
| [________________] | [________________] | [________________] | [________________] |
[________________________________]
[SIGNATURE]
About this template
- Last updated
- August 25, 2026
- Citations checked
- August 25, 2026
- Jurisdiction
- Utah
- Category
- Litigation & Court Documents
Legal authority
- Utah R. Civ. P. 26(b)(1), (b)(3)-(4)
- Utah R. Civ. P. 26(c)(2), (c)(5)-(6)
- Utah R. Civ. P. 26(d)(1)-(5), (e)-(f)
- Utah R. Civ. P. 33(a)-(d)
These are the filings that drive a lawsuit through the system: complaints, answers, motions, briefs, discovery requests and responses, and post-judgment papers. Each has its own format requirements under federal and state procedural rules, and each has a deadline that cannot be missed without consequences. Clean, procedurally correct filings move a case forward; sloppy ones invite motions to strike, amended responses, and avoidable delays.
Not legal advice
This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.
Checked against the law it cites
A reviewer verified this template's legal citations against the official source on August 25, 2026.
Utah R. Civ. P. 26(b)(1), (b)(3)-(4) (checked August 25, 2026): "Parties may discover any matter, not privileged, which is relevant to the claim or defense of any party if the discovery satisfies the standards of proportionality set forth below. The party seeking discovery always has the burden of showing proportionality and relevance."
Utah R. Civ. P. 26(c)(2), (c)(5)-(6) (checked August 25, 2026): "Except for cases exempt under paragraph (a)(3), a party may not seek discovery from any source before that party’s initial disclosure obligations are satisfied. Standard fact discovery per side (plaintiffs collectively, defendants collectively, and third-party defendants collectively) in each tier is as follows."
Utah R. Civ. P. 26(d)(1)-(5), (e)-(f) (checked August 25, 2026): "If a party learns that a disclosure or response is incomplete or incorrect in some important way, the party must timely serve on the other parties the additional or correct information if it has not been made known to the other parties. Every disclosure, request for discovery, response to a request for discovery, and objection to a request for discovery must be in writing and signed by at least one attorney of record or by the party if the party is not represented."
Utah R. Civ. P. 33(a)-(d) (checked August 25, 2026): "During standard discovery, any party may serve written interrogatories upon any other party, subject to the limits of Rule 26(c)(5). The responding party shall serve a written response within 28 days after service of the interrogatories. Each interrogatory shall be answered separately and fully in writing under oath or affirmation, unless it is objected to."
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