IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF [COUNTY]
[PLAINTIFF/CLAIMANT NAME],
a [STATE OF ORGANIZATION] [ENTITY TYPE],
Plaintiff,
v.
[DEFENDANT/RESPONDENT NAME],
a [STATE OF ORGANIZATION] [ENTITY TYPE],
Defendant.
No. [CASE NO.]
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT [DEFENDANT NAME]
[// GUIDANCE: Duplicate and reverse party designations if Defendant is propounding.]
TABLE OF CONTENTS
- Document Header ..................................................... 1
- Preliminary Statement ............................................... 2
- Definitions ......................................................... 3
- General Instructions ................................................ 5
- Specific Interrogatories ............................................ 8
- Verification ........................................................ 13
- Certificate of Service .............................................. 14
[Page numbers will auto-update in word-processing software.]
1. DOCUMENT HEADER
Effective Date: The date of service of these Interrogatories.
Governing Law & Procedure: Washington Superior Court Civil Rules (“CR”) and local rules of the above-captioned court.
Propounding Party: [PLAINTIFF NAME] (“Propounding Party”).
Responding Party: [DEFENDANT NAME] (“Responding Party”).
Set Number: First.
2. PRELIMINARY STATEMENT
Pursuant to CR 33 and CR 26, Propounding Party hereby serves the following Interrogatories on Responding Party. Each Interrogatory must be answered separately and fully, in writing, under oath, within the time provided by CR 33(b) or such other time as the Court may order.
3. DEFINITIONS
For purposes of these Interrogatories, the following terms have the meanings set forth below:
“Action” means the above-captioned lawsuit.
“Communication” means every manner of disclosure or exchange, whether oral or written, including telephone calls, e-mails, text messages, letters, memoranda, or meetings.
“Date” means the exact day, month, and year, if ascertainable, or the best available approximation.
“Document” is defined to be coextensive with the meaning of that term in CR 26 and includes electronically stored information (“ESI”).
“Identify” or “state the identity of” requires, as applicable:
a. For natural persons: full name, present or last-known residence and business addresses, telephone number, and employer or business affiliation at the relevant time.
b. For entities: full legal name, form of organization, principal place of business, and the identity of the entity’s representative most knowledgeable about the subject matter.
c. For Documents: title, date, author, recipients, type (e.g., letter, e-mail), and present custodian or location.
“You,” “Your,” or “Responding Party” means the party to whom these Interrogatories are directed, including all agents, employees, representatives, and attorneys.
4. GENERAL INSTRUCTIONS
4.1 Rule Compliance. These Interrogatories are propounded pursuant to Wash. Super. Ct. Civ. R. 33(a) and limited to forty (40) interrogatories, including discrete subparts. See Wash. Super. Ct. Civ. R. 33(a).
[// GUIDANCE: Remove or modify if parties stipulate to a different limit.]
4.2 Response Deadline. Answers and any objections must be served within thirty (30) days after service, except Responding Party may serve answers within forty (40) days after being served with the summons and complaint. Wash. Super. Ct. Civ. R. 33(b)(3).
4.3 Form of Answers. Each Interrogatory must be reproduced immediately preceding the answer. Answers shall be in writing and under oath. CR 33(a)(2).
4.4 Objections. If an objection is made, state all grounds with specificity. Any partially answerable portion must be answered. Boilerplate objections are improper.
4.5 Privilege & Work-Product. If any information is withheld under a claim of privilege or protection, produce a privilege log compliant with CR 26(b)(6), identifying the nature of the information, the privilege asserted, and sufficient detail to allow assessment of the claim.
4.6 Duty to Supplement. Responding Party has a continuing obligation to seasonably supplement or correct responses pursuant to CR 26(e).
4.7 Electronically Stored Information. If ESI is responsive, identify the systems, search methods, and metadata fields used. Confer promptly regarding any format issues.
4.8 Construction. The singular includes the plural and vice versa; the conjunctive includes the disjunctive and vice versa.
4.9 Instructions Not Exhaustive. These Instructions are in addition to, not in limitation of, the obligations imposed by the Civil Rules or any case scheduling order.
5. SPECIFIC INTERROGATORIES
[// GUIDANCE: Tailor the substance to the pleadings and claims. Add or delete interrogatories to fit within the 40-question limit, counting discrete subparts.]
Interrogatory No. 1
Identify every person likely to have discoverable information that You may use to support Your claims or defenses, and for each such person state the subject matter of the information the person possesses.
Interrogatory No. 2
For each allegation in Your [most recent pleading], state all facts supporting that allegation.
Interrogatory No. 3
State the amount of damages You contend to have sustained, itemizing each element of damage and the computation thereof.
Interrogatory No. 4
Identify all Documents that evidence, support, or relate to Your answer to Interrogatory No. 3.
Interrogatory No. 5
Describe in detail each affirmative defense asserted in Your [answer / responsive pleading], including the factual and legal bases for each defense.
Interrogatory No. 6
Identify all insurance agreements under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment that might be entered in this Action or to indemnify or reimburse for payments made to satisfy the judgment.
Interrogatory No. 7
If You contend that any Document produced by Propounding Party is inaccurate, forged, altered, or otherwise not genuine, identify each such Document and state the basis for Your contention.
Interrogatory No. 8
Identify all experts retained in anticipation of litigation or for trial, and for each expert state:
a. The subject matter on which the expert is expected to testify;
b. The substance of the facts and opinions to which the expert is expected to testify;
c. A summary of the grounds for each opinion.
Interrogatory No. 9
Describe the document retention and destruction policies that were in effect during the period [relevant period], including any litigation holds implemented for this Action.
Interrogatory No. 10
State each and every basis on which You deny liability for the claims asserted against You in this Action.
[…Continue until the desired number of interrogatories (≤ 40, including subparts) is reached…]
6. VERIFICATION
I, [NAME OF RESPONDING PARTY REPRESENTATIVE], declare under penalty of perjury under the laws of the State of Washington that I am authorized to make this Verification for Responding Party, that I have read the foregoing responses, and that the answers given are true and correct to the best of my knowledge, information, and belief.
Executed on ___ [DATE] , at ______, Washington.
[PRINTED NAME]
[Title/Position]
7. CERTIFICATE OF SERVICE
I hereby certify that on the ___ day of ____, 20__, I served the foregoing [Party]’s First Set of Interrogatories to [Opposing Party] on all counsel of record in the manner indicated below:
☐ Via ECF (where authorized)
☐ Via E-mail to: [EMAIL ADDRESSES]
☐ Via U.S. Mail, postage prepaid
☐ Via Hand Delivery / Legal Messenger
[NAME OF SENDER]
[Law Firm]
[Address]
[Telephone]
[Email]
[// GUIDANCE:
1. Review the case scheduling order for any court-specific discovery deadlines or quantity limits.
2. Consider adding local rule citations if the matter is pending in King, Pierce, Snohomish, or other counties with distinctive local discovery requirements.
3. For complex matters, confer with opposing counsel per CR 26(i) before serving, to streamline disputed requests and minimize motion practice.
4. Use plain-text drafting initially, then migrate to the court’s preferred word-processing format to preserve pagination and signature blocks.
5. Always maintain an unsigned “clean” version for exhibit use.
]