[NAME OF COURT]

[COUNTY], STATE OF WISCONSIN

________

[PLAINTIFF NAME],

Plaintiff,

Case No. [______]

v.

[DEFENDANT NAME],

Defendant.

________

PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

[// GUIDANCE: Title may be adapted to “Defendant’s First Set …,” “Second Set …,” etc. Wisconsin currently limits each party to one set of no more than twenty-five (25) interrogatories, including all discrete subparts. See Wis. Stat. ch. 804 discovery rules as amended 2018. If additional interrogatories are needed, obtain leave of court or the opposing party’s written stipulation before service.]

I. PRELIMINARY STATEMENT

Pursuant to Wisconsin Statutes chapter 804 and the Wisconsin Rules of Civil Procedure, Plaintiff propounds the following Interrogatories, which shall be answered fully and separately, under oath, within thirty (30) days after service hereof, unless the parties agree or the Court orders otherwise.
[// GUIDANCE: If these interrogatories accompany the Summons and Complaint, the responding party receives forty-five (45) days to respond.]

II. DEFINITIONS

For purposes of these Interrogatories, the following terms shall have the meanings set forth below:

1. “You,” “Your,” “Defendant,” or “[NAME]” means [DEFENDANT FULL LEGAL NAME], all predecessors, successors, parents, subsidiaries, affiliates, divisions, joint ventures, partners, officers, directors, employees, agents, representatives, and all other persons acting or purporting to act on its behalf.
2. “Document” and “Electronically Stored Information” or “ESI” are synonymous in meaning and equal in scope to the usage of those terms in Wis. Stat. ch. 804, and include but are not limited to writings, drawings, graphs, charts, photographs, audio/video recordings, emails, text messages, databases, and metadata.
3. “Communication” means every manner of transmitting or receiving information, whether orally, in writing, by electronic mail, text message, social media, or otherwise.
4. “Identify” (when referring to a person) means to state the person’s full name, present or last-known business address, present or last-known residence address, present or last-known telephone number, and present or last-known employer and position.
5. “Identify” (when referring to a document or ESI) means to state (a) the title or identifying label, (b) the date, (c) the author(s) and recipient(s), (d) the general subject matter, and (e) the location or custodian.
6. “Incident” means the events giving rise to the claims and defenses in this litigation as further described in the pleadings.
7. “Person” means any natural individual or any legal or governmental entity.
8. “Relate to,” “relating to,” or “concerning” means directly or indirectly mentioning, describing, evidencing, summarizing, referring to, constituting, or having any logical connection with the subject matter.

[// GUIDANCE: Add or delete definitions to suit case specifics. Keep definitions alphabetized.]

III. GENERAL INSTRUCTIONS

1. Answer each Interrogatory separately and fully, in writing, and under oath.
2. Where the answer is not presently known or available, so state, and provide the information on which You can rely; supplement promptly as additional information becomes known.
3. If any Interrogatory is objected to in whole or in part:
   a. State with specificity all grounds for the objection;
   b. If You withhold information based on privilege, work-product, or other protection, produce a privilege log identifying the nature of the document, the author, recipient, date, and basis for the claim of privilege sufficient to enable other parties to assess the claim, consistent with Wisconsin discovery rules.
4. These Interrogatories are deemed continuing. Pursuant to Wis. Stat. ch. 804, You must seasonably amend or supplement any response that is in some material respect incomplete or incorrect.
5. Whenever a name or document is requested, provide all known aliases, code names, file names, or abbreviations.
6. Where the plural is used, it shall include the singular and vice versa; the masculine, feminine, and neuter shall include each of the other genders.
7. Unless otherwise indicated, the relevant time period for these Interrogatories is [START DATE] through the present.

[// GUIDANCE: Customize the relevant period to match pleadings and claims.]

IV. INTERROGATORIES

1. Identify every person You believe has knowledge of the facts alleged in the pleadings, and for each such person state the subject matter of his or her knowledge.

2. State in detail the factual basis for each affirmative defense asserted in Your Answer.

3. Describe all oral or written communications between You and Plaintiff regarding the Incident, including date, participants, and substance.

4. Identify all documents and ESI that support Your contention that [SPECIFIC DEFENSE/CLAIM], and describe how each supports that contention.

5. State the name, last known address, and telephone number of every expert witness You have retained or specially employed in this action, and for each expert state the subject matter upon which he or she is expected to testify.

6. Itemize and describe each category of damages You claim or believe Plaintiff may have sustained, and state the method of calculation for each category.

7. State all insurance agreements under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment in this action or to indemnify or reimburse payments made to satisfy the judgment.

8. Identify all photographs, videos, or audio recordings that relate to the Incident, stating the date taken, the author, current custodian, and a brief description of the contents.

9. Describe any investigation conducted by or on Your behalf concerning the Incident, including the identity of investigators and the materials generated or collected.

10. State whether You contend any third party is wholly or partially at fault for the claims asserted, and if so, identify such third party and state the factual basis for Your contention.

11. Identify all communications with any governmental or regulatory body concerning the Incident.

12. Describe all efforts You undertook to preserve documents and ESI relating to the Incident after You reasonably anticipated litigation.

13. State the date, time, and place of any meeting where the Incident was discussed among Your employees or agents and identify all persons present.

14. Identify each instance in the past ten (10) years where You have been a party to litigation involving allegations similar to those in this action, stating the caption, case number, jurisdiction, disposition, and current status.

15. State the factual basis for Your contention that Plaintiff was contributorily negligent or otherwise at fault, including the specific acts or omissions Plaintiff allegedly committed.

[// GUIDANCE: This sample provides 15 interrogatories. Add up to 10 more (25 total, including any discrete subparts) as required by the case. Use sub-numbering (e.g., 15(a)–(d)) sparingly; each distinct question counts toward the 25-interrogatory cap.]

V. VERIFICATION

I, [NAME], being first duly sworn, state that I am [TITLE/POSITION] for Defendant, that I have read the foregoing answers to Interrogatories, know the contents thereof, and that said answers are true and correct to the best of my knowledge, information, and belief.

[NAME]
[DATE]

Subscribed and sworn before me
this ___ day of ____, 20__.

Notary Public, State of Wisconsin
My commission expires: ____

[// GUIDANCE: Wisconsin requires interrogatory answers to be signed under oath by the party, not merely by counsel. Notarization is customary though not expressly required; confirm with local practice.]

VI. CERTIFICATE OF SERVICE

I certify that on [DATE], I caused a true and correct copy of Plaintiff’s First Set of Interrogatories to Defendant to be served upon all counsel of record via [METHOD OF SERVICE] pursuant to Wis. Stat. ch. 801 and ch. 804.

[ATTORNEY NAME]
State Bar No. [__]
[LAW FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]
Counsel for Plaintiff

[// GUIDANCE:
1. Track the running interrogatory count; multiple subparts may count individually toward the cap.
2. Consider entering into a Stipulation for Additional Discovery if 25 interrogatories will be insufficient.
3. After answers are served, evaluate the need for follow-up discovery, depositions, or motions to compel.
4. Maintain a privilege log that satisfies Wisconsin’s specificity requirements to avoid waiver.
5. For ESI, coordinate with opposing counsel on format, search protocols, and metadata to minimize disputes under Wis. Stat. § 804.09(12) (electronically stored information).]