Washington State Court Discovery -- Interrogatories

WASHINGTON STATE COURT INTERROGATORIES

Comprehensive Discovery Template -- 30 Sample Interrogatories

COURT CAPTION

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF [________________________________]

PROPOUNDING PARTY INFORMATION

PRELIMINARY STATEMENT

Pursuant to Washington Superior Court Civil Rule ("CR") 33 and CR 26, [________________________________] ("Propounding Party") hereby propounds the following Interrogatories upon [________________________________] ("Responding Party").

Each Interrogatory must be answered separately and fully, in writing, under oath, within thirty (30) days after service of these Interrogatories, or within forty (40) days after service of the summons and complaint if served concurrently therewith. CR 33(b)(3).

Responding Party is required to furnish all information available, including information in the possession, custody, or control of Responding Party's agents, employees, attorneys (to the extent not protected by privilege), and other representatives.

DEFINITIONS

For purposes of these Interrogatories, the following defined terms shall have the meanings set forth below. These definitions are intended to be broadly construed and supplement any definitions provided by the Civil Rules.

1. "Action" means the above-captioned lawsuit, including all claims, counterclaims, cross-claims, and third-party claims.

2. "Communication" means every manner or means of disclosure, transfer, or exchange of information, whether oral, written, or electronic, including but not limited to: telephone calls, voicemail messages, video calls, in-person conversations, letters, memoranda, emails, text messages (SMS/MMS), instant messages, social media messages, postings, or any other transmission of information by any medium.

3. "Date" means the exact day, month, and year, if ascertainable; or, if not, the best approximation thereof, identified as approximate.

4. "Describe" or "Describe in Detail" means to provide a comprehensive narrative account including all relevant facts, circumstances, dates, locations, persons involved, and the substance of any communications.

5. "Document" or "Documents" is defined to be coextensive with the meaning of that term in CR 26(b) and CR 34, and includes all writings, drawings, graphs, charts, photographs, phone records, electronically stored information ("ESI"), and other data compilations from which information can be obtained, regardless of the medium on which they are stored.

6. "ESI" means electronically stored information, including emails, databases, spreadsheets, word processing files, presentation files, image files, text files, voicemail, instant messages, social media content, metadata, and any other data stored in electronic format.

7. "Identify" (as to a Person) means to state: (a) full legal name; (b) present or last-known residential address; (c) present or last-known business address; (d) telephone number(s); (e) email address(es); (f) employer or business affiliation at the relevant time; and (g) relationship to any party in this Action.

8. "Identify" (as to a Document) means to state: (a) title or description; (b) date; (c) author(s) or creator(s); (d) recipient(s) or addressee(s); (e) type (e.g., letter, email, contract, invoice, report); (f) Bates number (if produced); and (g) present custodian or location.

9. "Identify" (as to a Communication) means to state: (a) the date; (b) the form (oral, written, electronic); (c) all participants or persons present; (d) the substance or content; and (e) the location or custodian of any record of the communication.

10. "Incident" means the events, occurrences, transactions, or circumstances giving rise to the claims and/or defenses in this Action, as alleged in the pleadings.

11. "Person" means any natural person, corporation, partnership, limited liability company, association, governmental entity, or any other legal entity.

12. "Relating to" or "Related to" or "Concerning" means referring to, reflecting, evidencing, describing, constituting, mentioning, pertaining to, or being in any way logically or factually connected with the subject matter referenced.

13. "You," "Your," or "Responding Party" means the party to whom these Interrogatories are directed, including all agents, employees, officers, directors, representatives, attorneys (to the extent not protected by privilege), predecessors, successors, and assigns.

GENERAL INSTRUCTIONS

Instruction No. 1 -- Interrogatory Limit. These Interrogatories are propounded pursuant to CR 33(a). Washington CR 33 does not impose a statewide numerical limit on interrogatories. However, many counties impose limits through local rules (commonly 40 interrogatories including discrete subparts). This set is drafted to comply with the local rules of [________________________________] County. Propounding Party reserves the right to serve supplemental interrogatories up to the maximum permitted by the applicable local rule or by stipulation of the parties.

Instruction No. 2 -- Response Deadline and Form. Answers and any objections must be served within 30 days after service. CR 33(b)(3). If served with the summons and complaint, Responding Party has 40 days to respond. Each Interrogatory must be reproduced immediately preceding the answer. CR 33(a)(2). Answers must be in writing and under oath.

Instruction No. 3 -- Oath Requirement. Answers must be signed under oath by the Responding Party, or by an authorized officer or agent if the party is a corporation, partnership, association, or governmental entity. CR 33(a)(2).

Instruction No. 4 -- Objections. If an objection is made, state all grounds with specificity. Boilerplate or blanket objections are improper and may be deemed a waiver. If an Interrogatory is objectionable only in part, the objection must specify the part objected to and the answer must respond to the remainder. CR 33(b)(4).

Instruction No. 5 -- Privilege Log. If any information is withheld on the basis of privilege, work-product protection, or any other ground, Responding Party must produce a privilege log compliant with CR 26(b)(6) identifying: (a) the nature of the document or communication; (b) the date; (c) the author and all recipients; (d) the general subject matter; and (e) the specific privilege or protection asserted.

Instruction No. 6 -- Duty to Supplement. Responding Party has a continuing obligation to seasonably supplement or correct its responses as required by CR 26(e), including information regarding the identity of persons with knowledge, expert witnesses, and any response that was incorrect or incomplete when made.

Instruction No. 7 -- Business Records Option. Where the answer may be derived from business records and the burden of deriving the answer is substantially the same for both parties, Responding Party may specify the records from which the answer may be derived and afford a reasonable opportunity to examine and copy them. CR 33(c). The specification must be sufficiently detailed to locate and identify the records.

Instruction No. 8 -- ESI. If responsive information includes ESI, identify the systems, platforms, custodians, search methods, and date ranges used. Confer promptly regarding format or accessibility issues per CR 26(b).

Instruction No. 9 -- Construction. The singular includes the plural and vice versa. "And" and "or" shall be construed conjunctively or disjunctively as necessary to make the Interrogatory inclusive. The present tense includes the past tense and vice versa.

Instruction No. 10 -- Time Period. Unless otherwise specified, each Interrogatory covers the time period from [__/__/____] to the present.

INTERROGATORIES

PART A: PARTIES AND WITNESSES

INTERROGATORY NO. 1 -- Party Identification

State Your full legal name, all former names or aliases, date of birth, current residential address, current business address, and all telephone numbers and email addresses currently in use. If Responding Party is an entity, state its full legal name, form of organization, state and date of formation, principal place of business, and registered agent in Washington.

INTERROGATORY NO. 2 -- Persons with Knowledge

Identify every Person known to You who is likely to have discoverable information relevant to the claims or defenses in this Action, and for each such Person state: (a) the Person's relationship to any party; (b) the subject matter(s) about which the Person has knowledge; and (c) the general nature of the information the Person possesses.

INTERROGATORY NO. 3 -- Witnesses to the Incident

Identify every Person who witnessed, was present during, or has first-hand knowledge of any part of the Incident, and for each such Person describe the Person's location and actions at the time of the Incident.

INTERROGATORY NO. 4 -- Statements Obtained

Identify every statement (written, recorded, or otherwise memorialized) obtained from any Person concerning the Incident or the subject matter of this Action, including: (a) the identity of the Person who gave the statement; (b) the date it was made; (c) the identity of the Person or entity who obtained the statement; and (d) the form in which it was recorded (e.g., written narrative, audio recording, video, transcript).

PART B: FACTUAL BASIS FOR CLAIMS OR DEFENSES

INTERROGATORY NO. 5 -- Factual Basis for Claims or Defenses

For each claim or affirmative defense asserted in Your most recent pleading, state all facts upon which You rely to support that claim or defense, including the date(s), location(s), Person(s) involved, and the specific conduct or events that form the basis thereof.

INTERROGATORY NO. 6 -- Basis for Denials

For each allegation in [Propounding Party's] most recent pleading that You deny, state all facts upon which You base Your denial.

INTERROGATORY NO. 7 -- Affirmative Defenses

For each affirmative defense asserted in Your responsive pleading, describe in detail: (a) the factual basis for the defense; (b) the legal theory supporting the defense; (c) all Persons with knowledge of facts relating to the defense; and (d) all Documents that support or relate to the defense.

PART C: DAMAGES

INTERROGATORY NO. 8 -- Damages Calculation

State the total amount of damages You contend to have sustained as a result of the matters alleged in this Action, and itemize each element of damage (including but not limited to economic loss, lost profits, property damage, medical expenses, lost wages, pain and suffering, emotional distress, and any other claimed damages), providing the computation and factual basis for each element.

INTERROGATORY NO. 9 -- Medical Treatment

If You claim damages for personal injury, identify each healthcare provider (physician, hospital, clinic, therapist, chiropractor, or other provider) from whom You have received examination, treatment, or consultation relating to injuries claimed in this Action, and for each state: (a) the provider's name and address; (b) the dates of treatment; (c) the nature of the treatment or services provided; (d) the diagnosis or diagnoses; and (e) the total charges billed and amounts paid (by You, by insurance, or by any other source).

INTERROGATORY NO. 10 -- Prior and Subsequent Medical History

Identify all healthcare providers from whom You received examination or treatment for the same or similar conditions as those claimed in this Action during the five (5) years preceding the Incident and at any time after the Incident, including: (a) the provider's name and address; (b) dates of treatment; and (c) the conditions treated.

INTERROGATORY NO. 11 -- Lost Income and Employment

If You claim damages for lost income, lost earning capacity, or employment-related losses, state: (a) Your employer(s) at the time of the Incident and for two (2) years preceding it; (b) Your job title(s) and duties; (c) Your rate of pay, hours worked, and gross earnings for the twelve (12) months preceding the Incident; (d) the dates on which You were unable to work as a result of the Incident; (e) the total amount of income You claim to have lost; and (f) whether You received any disability benefits, workers' compensation, or other replacement income.

INTERROGATORY NO. 12 -- Property Damage

If You claim damages for property damage, identify the property damaged, describe the nature and extent of the damage, state the fair market value of the property before and after the damage, identify any repair or replacement costs incurred, and identify any Person or entity that performed repairs.

INTERROGATORY NO. 13 -- Mitigation

Describe all steps You have taken to mitigate Your damages, including any efforts to obtain alternative employment, alternative business arrangements, medical treatment, or other measures to reduce the losses You claim.

PART D: INSURANCE

INTERROGATORY NO. 14 -- Insurance Coverage

Identify all insurance agreements (including primary, excess, umbrella, and self-insurance) under which any insurer may be liable to satisfy part or all of a judgment in this Action or to indemnify or reimburse for payments made to satisfy such judgment. For each such agreement state: (a) the name and address of the insurer; (b) the policy number; (c) the effective dates; (d) the coverage limits (per occurrence and aggregate); (e) the deductible or self-insured retention; and (f) whether coverage has been denied, reserved, or is disputed. See CR 26(b)(2).

PART E: EXPERT WITNESSES

INTERROGATORY NO. 15 -- Retained Expert Witnesses

Identify each expert retained or specially employed in anticipation of litigation or preparation for trial in this Action, and for each state: (a) the expert's name, address, and professional qualifications; (b) the subject matter on which the expert is expected to testify; (c) the substance of the facts and opinions to which the expert is expected to testify; (d) a summary of the grounds for each opinion; (e) the expert's compensation rate for this engagement; and (f) a list of cases in which the expert has testified at trial or by deposition within the preceding four years.

INTERROGATORY NO. 16 -- Non-Testifying Experts

Without waiving any work-product protection, identify any expert who has been consulted in connection with this Action but who is not expected to testify at trial, and state the subject matter of the consultation.

PART F: DOCUMENTS AND EVIDENCE

INTERROGATORY NO. 17 -- Documents Supporting Claims or Defenses

Identify all Documents that You believe support, evidence, or relate to Your claims or defenses in this Action, including the custodian or location of each Document.

INTERROGATORY NO. 18 -- Agreements and Contracts

Identify all written or oral agreements, contracts, or understandings between any parties to this Action (or between You and any third party) that relate to the subject matter of this Action, and for each state: (a) the date; (b) the parties; (c) the subject matter; and (d) the custodian or location of any written version.

INTERROGATORY NO. 19 -- Photographs, Videos, and Recordings

Identify all photographs, videos, audio recordings, or other visual or audio media relating to the Incident or the subject matter of this Action, including: (a) the date created; (b) the identity of the creator; (c) a description of the content; and (d) the current custodian or location.

PART G: COMMUNICATIONS

INTERROGATORY NO. 20 -- Communications Between Parties

Identify all Communications between You and any other party to this Action relating to the subject matter of this Action that occurred before the filing of the Complaint, including the date, participants, form, and substance of each Communication.

INTERROGATORY NO. 21 -- Communications with Third Parties

Identify all Communications between You and any non-party concerning the Incident or the subject matter of this Action, including: (a) the identity of the third party; (b) the date and form of the Communication; and (c) the substance of the Communication.

INTERROGATORY NO. 22 -- Social Media

Identify all social media accounts (including but not limited to Facebook, Instagram, X/Twitter, TikTok, LinkedIn, Snapchat, Reddit, YouTube, and any other platform) that You have maintained, used, or posted to from [__/__/____] to the present. For each account state: (a) the platform; (b) the username or handle; (c) whether the account is currently active; and (d) whether You have posted, shared, or commented on any content relating to the Incident or this Action.

PART H: PRIOR CLAIMS AND LITIGATION

INTERROGATORY NO. 23 -- Prior Lawsuits

Identify every lawsuit, arbitration, or administrative proceeding in which You have been a party (whether as plaintiff, defendant, claimant, respondent, petitioner, or intervenor) during the past ten (10) years, including: (a) the case name and number; (b) the court or tribunal; (c) the nature of the claims; (d) the outcome or current status; and (e) the names of counsel who represented You.

INTERROGATORY NO. 24 -- Prior Claims for Similar Injuries or Damages

If You claim personal injury or property damage in this Action, identify every other claim You have made for personal injury, property damage, disability, or workers' compensation during the past ten (10) years, including: (a) the date of the incident giving rise to the claim; (b) the nature of the injuries or damages claimed; (c) the entity or Person against whom the claim was made; and (d) the outcome.

PART I: DOCUMENT RETENTION AND ESI

INTERROGATORY NO. 25 -- Document Retention and Litigation Hold

Describe Your document retention and destruction policies that were in effect during the time period relevant to this Action, including: (a) any policies governing the retention or deletion of emails, text messages, and other ESI; (b) any changes to such policies since the events giving rise to this Action; and (c) any litigation holds implemented in connection with this Action (including the date implemented, the scope, and the identity of the Person who authorized the hold).

INTERROGATORY NO. 26 -- Electronic Systems and Databases

Identify all electronic systems, databases, applications, and platforms on which Documents or ESI relating to this Action have been created, stored, transmitted, or received, including: (a) the name and type of each system; (b) the custodian(s) with access; and (c) any backup or archival systems.

PART J: INCIDENT-SPECIFIC INTERROGATORIES

INTERROGATORY NO. 27 -- Sequence of Events

Describe in detail the complete sequence of events that You contend led to, occurred during, and followed the Incident, including the date(s), time(s), location(s), weather or environmental conditions (if relevant), and the identity and actions of each Person involved.

INTERROGATORY NO. 28 -- Comparative Fault and Contributory Negligence

If You contend that any Person (including Propounding Party, any co-party, or any non-party) bears fault, responsibility, or liability for the Incident or the damages claimed, identify each such Person and describe: (a) the conduct You contend was negligent, wrongful, or otherwise contributed to the Incident; and (b) the percentage of fault, if any, You attribute to each such Person. See RCW 4.22.070 (Washington comparative fault).

INTERROGATORY NO. 29 -- Prior Notice or Knowledge

Describe any knowledge, notice, or awareness that You or Your agents had, before the Incident, of the conditions, circumstances, hazards, or risks that You contend contributed to or caused the Incident. Include the date on which You first became aware, the source of the information, and any actions taken in response.

INTERROGATORY NO. 30 -- Applicable Standards, Rules, and Regulations

Identify all rules, regulations, policies, procedures, guidelines, protocols, industry standards, or codes of conduct that You contend are applicable to the conduct at issue in this Action, and for each state: (a) the title or citation; (b) the issuing authority; (c) the relevant provisions; and (d) how You contend such standard was or was not violated.

VERIFICATION

VERIFICATION UNDER PENALTY OF PERJURY

I, [________________________________], declare under penalty of perjury under the laws of the State of Washington that the following is true and correct:

1. I am the:
   ☐ Responding Party individually
   ☐ Authorized [officer / agent / representative] of [________________________________], the Responding Party in this Action

2. I have read the foregoing responses to [Propounding Party's] First Set of Interrogatories.

3. The answers given are true and correct to the best of my knowledge, information, and belief, after reasonable inquiry.

4. I understand that a false statement made under penalty of perjury is punishable under RCW 9A.72.020 (perjury in the first degree) or RCW 9A.72.030 (perjury in the second degree).

I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct.

Executed on [__/__/____], at [________________________________], Washington.

________________________________________
[________________________________]
[Printed Name]
[Title/Position, if applicable]

CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], I caused a true and correct copy of the foregoing [Propounding Party's] First Set of Interrogatories to [Responding Party] to be served on all counsel of record and unrepresented parties as follows:

[________________________________]
[Attorney Name], Attorney for [Party]
[________________________________] [Firm Name]
[________________________________] [Address]
[________________________________] [City, State ZIP]
[________________________________] [Email]
[________________________________] [Telephone]

Method of Service:

☐ Washington State Superior Court Electronic Filing (eFiling)
☐ Electronic mail to the address(es) listed above (by agreement of the parties)
☐ U.S. first-class mail, postage prepaid
☐ Hand delivery / legal messenger
☐ Facsimile transmission to: [________________________________]

________________________________________
[________________________________]
[Attorney Name], WSBA No. [________________________________]
Attorney for [Propounding Party]
[________________________________] [Firm Name]
[________________________________] [Address]
[________________________________] [City, State ZIP]
Telephone: [________________________________]
Email: [________________________________]

WASHINGTON DISCOVERY PRACTICE NOTES

These notes are for practitioner reference only. Remove before serving.

CR 33 -- Key Rules and Limitations

1. No Statewide Numerical Limit. Unlike the federal rules (which impose a 25-interrogatory limit under FRCP 33(a)(1)), Washington CR 33 does not impose a statewide cap on the number of interrogatories. However, virtually all counties impose limits through local rules.

2. Common County Interrogatory Limits:

Always verify the applicable local rule before serving. Limits and subpart-counting rules vary by county and case track.

3. Subparts Counting Rules. Discrete subparts that ask about separate and unrelated subjects generally count as separate interrogatories. Related subparts that merely ask for details about the same topic (e.g., "identify the person" and "describe the relationship") are typically counted as a single interrogatory. Be conservative in drafting -- courts can sustain objections that subparts inflate the true interrogatory count beyond the local limit.

4. Response Deadline. 30 days from service (CR 33(b)(3)); 40 days if served with summons and complaint.

5. Format Requirement. Each interrogatory must be reproduced immediately preceding the answer, with space for the response. CR 33(a)(2).

6. Oath Requirement. Answers are signed under oath by the party; objections are signed by the attorney. CR 33(a)(2).

7. Business Records Option (CR 33(c)). Where the answer can be derived from the responding party's business records, and the burden of deriving the answer is substantially the same for both parties, the responding party may specify the records and provide a reasonable opportunity to examine and copy them. The specification must be sufficiently detailed to locate the relevant documents -- a general reference to "all our files" is insufficient.

CR 26 -- Discovery Scope and Conference Requirement

8. Scope of Discovery (CR 26(b)). Parties may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter of the pending action. Information need not be admissible at trial if it appears reasonably calculated to lead to the discovery of admissible evidence.

9. CR 26(i) -- Conference Requirement. Before filing any discovery motion under CR 37, the moving party must certify that a good-faith effort was made to confer with opposing counsel to resolve the dispute without court intervention. Many courts enforce this requirement strictly and will deny motions lacking the required certification. Conduct the conference early and memorialize it in writing.

10. Proportionality. Although CR 26(b) does not contain an express proportionality requirement like FRCP 26(b)(1), Washington courts may limit discovery that is unreasonably cumulative, duplicative, obtainable from a more convenient source, or disproportionate to the needs of the case. CR 26(b)(1).

CR 37 -- Sanctions for Failure to Respond

11. Motion to Compel (CR 37(a)). If a party fails to answer an interrogatory or provides evasive or incomplete answers, the propounding party may move for an order compelling a response. The court shall award reasonable expenses, including attorney fees, to the prevailing party unless the opposing party's position was substantially justified or other circumstances make an award unjust.

12. Sanctions (CR 37(b)). If a party fails to comply with a court order compelling discovery, the court may impose sanctions including: establishing designated facts as admitted; prohibiting the disobedient party from introducing evidence on certain matters; striking pleadings or parts thereof; staying proceedings; dismissing the action or entering default judgment; or holding the party in contempt.

Verification and Perjury

13. RCW 9A.72.085 -- Unsworn Declarations. Washington permits unsworn written declarations made under penalty of perjury as a substitute for sworn statements. The declaration must recite: "I certify (or declare) under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct," followed by the declarant's signature and date. This is the standard verification format for interrogatory answers.

14. Perjury Statutes. False answers under oath may constitute perjury under RCW 9A.72.020 (first degree -- material false statement in an official proceeding) or RCW 9A.72.030 (second degree).

Strategic Considerations

15. Coordinate with Other Discovery. Interrogatories are most effective when combined with requests for production (CR 34) and requests for admission (CR 36). Use interrogatories to identify witnesses and documents, then use document requests to obtain the identified materials.

16. Contention Interrogatories. Washington courts generally permit contention interrogatories (e.g., "State all facts supporting your claim for...") but may defer answers until a reasonable period for discovery has elapsed. Consider timing relative to the case schedule.

17. Avoid Overly Broad Interrogatories. Courts may sustain objections to interrogatories that are unduly burdensome, oppressive, or seek information equally available to the propounding party. Focus on information uniquely within the responding party's knowledge.

18. Pattern Interrogatories. King County has adopted pattern interrogatories for personal injury, motor vehicle, and general civil cases. Using pattern interrogatories in King County may entitle the propounding party to additional supplemental interrogatories beyond the standard 40-interrogatory limit. Check King County LCR 33 for current requirements.

19. Case Scheduling Order. Always review the case scheduling order for discovery deadlines, any court-specific limitations on interrogatory counts, and requirements for CR 26(f) discovery conference or discovery plans. Many courts set a firm discovery cutoff date.

20. Amended and Supplemental Responses. If Responding Party's initial answers are incomplete or become inaccurate, the duty to supplement under CR 26(e) requires seasonable correction. Consider sending a meet-and-confer letter before filing a motion to compel supplementation -- courts expect good-faith resolution efforts before granting relief.

Sources and References

• Washington CR 33 (Interrogatories to Parties): https://www.courts.wa.gov/court_rules/?fa=court_rules.display&group=sup&set=cr&ruleid=supcr33
• Washington CR 26 (General Provisions Governing Discovery): https://www.courts.wa.gov/court_rules/?fa=court_rules.display&group=sup&set=cr&ruleid=supcr26
• Washington CR 37 (Failure to Make Discovery; Sanctions): https://www.courts.wa.gov/court_rules/?fa=court_rules.display&group=sup&set=cr&ruleid=supcr37
• RCW 9A.72.085 (Unsworn Declarations Under Penalty of Perjury): https://app.leg.wa.gov/rcw/default.aspx?cite=9A.72.085
• RCW 9A.72.020 (Perjury in the First Degree): https://app.leg.wa.gov/rcw/default.aspx?cite=9A.72.020
• RCW 4.22.070 (Comparative Fault): https://app.leg.wa.gov/rcw/default.aspx?cite=4.22.070
• King County Local Civil Rules: https://kingcounty.gov/en/dept/dja/courts-jails-legal-system/superior-court-local-rules/local-civil-rules
• Washington State Courts -- Court Rules: https://www.courts.wa.gov/court_rules/
• Amendments to CR 26 and CR 30 (Washington State Bar): https://wabarnews.org/2024/11/12/amendments-to-cr-26-and-30-will-change-discovery-and-deposition-practice/