State Court Discovery - Interrogatories - Virginia
[Plaintiff's / Defendant's] First Set of Interrogatories to [Party]
In the Circuit Court of [COUNTY OR CITY], Virginia
| Party | Role |
|---|---|
| [PLAINTIFF NAME] | Plaintiff |
| v. | Case No. [CASE NUMBER] |
| [DEFENDANT NAME] | Defendant |
Requesting party: [NAME] Responding party: [NAME]
Date served: [__/__/____]
[REQUESTING PARTY] serves the following interrogatories under Va. Sup. Ct. R. 4:8. These requests concern [IDENTIFY THE CLAIMS OR DEFENSES AT ISSUE] and the period [START DATE] through [END DATE]. Replace or delete questions that do not fit this case.
Instructions
- Answer each interrogatory separately and fully in writing under oath, except to the extent of a specific objection. Answer any part that is not objected to. Va. Sup. Ct. R. 4:8(d).
- Serve answers and any objections within 21 days after service of these interrogatories. For a defendant, the Rule also permits a 28-day period measured from service of the complaint when that exception applies. The court may set a shorter or longer time. Va. Sup. Ct. R. 4:8(d).
- Count all parts and subparts, together with earlier interrogatories from this party to the same recipient, before service. Without leave for good cause, the cumulative limit is 30. Va. Sup. Ct. R. 4:8(g).
- These interrogatories and responses ordinarily are not filed unless the court directs filing. Va. Sup. Ct. R. 4:8(c).
For these requests, "You" means the responding party. "Identify" a person by name, role, and known contact information; identify a document by date, type, author or custodian, and present location if known.
Interrogatories
No. 1. Identify the persons who have knowledge of the events alleged in paragraph(s) [NUMBERS] of the [COMPLAINT / ANSWER], and state the subject of each person's knowledge.
No. 2. State the facts supporting your [SPECIFIC ALLEGATION OR DENIAL] in paragraph [NUMBER] of your [PLEADING], identifying the persons and documents on which you rely.
No. 3. Identify each communication between [PARTIES OR IDENTIFIED PEOPLE] concerning [SPECIFIC EVENT] during [DATE RANGE], stating its date, participants, form, and subject.
No. 4. Identify the documents in your possession, custody, or control that support your [SPECIFIED CLAIM OR DEFENSE], including their present custodian.
No. 5. State the facts supporting the [NAMED AFFIRMATIVE DEFENSE OR RESPONSE] pleaded in paragraph [NUMBER], identifying the persons and documents on which you rely.
No. 6. State your computation of [SPECIFIED CATEGORY OF DAMAGES OR OFFSET] for [PERIOD], including the figures and records used.
No. 7. Identify any other person you contend caused or contributed to [SPECIFIED EVENT OR LOSS], and state the factual basis for that contention.
Certificate of service
I certify that on [__/__/____] I served these interrogatories on the following counsel of record by the method stated below.
Recipient and address: [________________________________]
Method: ☐ Delivery ☐ Same-day or next-day commercial delivery ☐ Facsimile ☐ Mail ☐ Electronic mail permitted by Rule 1:17 or signed written consent
Date of delivery, dispatch, transmission, or mailing: [__/__/____]
If electronic mail was used outside an electronically filed case, signed consent was obtained and this certificate was separately mailed or faxed on the service date: ☐ Yes ☐ Not applicable
Signature: [________________________________] Printed name: [________________________________]
Virginia State Bar number, if counsel: [________] Address: [________________________________]
Telephone: [________] Business email, if used: [________________________________]
Sources
- Rules of Supreme Court of Virginia, Rules 4:8, 4:1(b), and 1:12.
About this template
- Last updated
- October 2, 2026
- Citations checked
- October 2, 2026
- Jurisdiction
- Virginia
- Category
- Litigation & Court Documents
Legal authority
- Va. Sup. Ct. R. 4:8
- Va. Sup. Ct. R. 4:1(b)
- Va. Sup. Ct. R. 1:12
- Va. Sup. Ct. R. 1:17(e)
- Va. Sup. Ct. R. 1:4(l)
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 October 2, 2026.
Va. Sup. Ct. R. 4:8(a), (d) (checked October 2, 2026): "Any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is a public or private corporation or a partnership or association or governmental agency, by any officer or agent, who must furnish such information as is available to the party. The party upon whom the interrogatories have been served must serve a copy of the answers, and objections if any, within 21 days after the service of the interrogatories, except that a defendant may serve answers or objections within 28 days after service of the complaint upon that defendant. The court may allow a shorter or longer time."
Va. Sup. Ct. R. 4:8(c), (g) (checked October 2, 2026): "Interrogatories and answers or objections thereto should not be filed unless the court directs such filing on its own initiative or upon the request of any party prior to or during the trial. No party may serve upon any other party, at any one time or cumulatively, more than thirty written interrogatories, including all parts and sub-parts without leave of court for good cause shown."
Va. Sup. Ct. R. 4:1(b)(1) (checked October 2, 2026): "Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery or to the claim or defense of any other party, including the existence, description, nature, custody, condition and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter."
Va. Sup. Ct. R. 1:12 (checked October 2, 2026): "All pleadings, motions and other papers served after the initial process in an action and not required to be served otherwise and requests for subpoenas duces tecum must be served by delivering, dispatching by commercial delivery service for same-day or next-day delivery, transmitting by facsimile, transmitting by electronic mail when Rule 1:17 so provides or when consented to in writing signed by the person to be served, or by mailing, a copy to each counsel of record on or before the day of filing."
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