State Court Discovery - Interrogatories - Wyoming

WYOMING STATE COURT INTERROGATORIES

IN THE DISTRICT COURT OF [________________________________] COUNTY, WYOMING

[________________________________] JUDICIAL DISTRICT

Civil Action No.: [________________________________]

[PLAINTIFF'S / DEFENDANT'S] [FIRST / ____] SET OF INTERROGATORIES TO [PARTY]

Under Wyo. R. Civ. P. 26 and 33, [PROPOUNDING PARTY] serves these interrogatories on [RESPONDING PARTY]. Each interrogatory must be answered separately and fully in writing under oath unless specifically objected to.

USE GATE

☐ Confirmed that the Wyoming Rules of Civil Procedure govern this action and that no specialized rule, local practice, stipulation, protective order, or case-management order changes this discovery

☐ Counted every interrogatory and discrete subpart; absent stipulation or court order, the total does not exceed 25 under Rule 33(a)(1)

☐ Calculated the response date from service; Rule 33(b)(2) supplies a 30-day default but permits a shorter or longer time by Rule 29 stipulation or court order

☐ Tailored every request to nonprivileged matter relevant to a claim or defense and proportional to the needs of this case under Rule 26(b)

☐ Removed requests duplicated by disclosures, prior discovery, pleadings, or information already available from a more convenient source

☐ Checked the governing service method, electronic-filing rules, privacy protections, and any confidential-information order

Service date: [__/__/____]

Calculated response date: [__/__/____]

Interrogatory count, including discrete subparts: [____]

DEFINITIONS

1. "You" or "Responding Party" means [________________________________]. For an entity, answers must be given by an officer or agent who furnishes the information available to the party under Rule 33(b)(1)(B).

2. "Incident" or "Transaction" means [describe the event, contract, occurrence, or conduct at issue: ________________________________].

3. "Communication" means an oral, written, or electronic exchange of information material to the claims or defenses, including a letter, email, text message, recorded call, meeting, or direct message.

4. "Document" includes writings, drawings, graphs, charts, photographs, sound recordings, images, and electronically stored information within Rule 34(a)(1)(A).

5. "Identify," for a person, means state the person's name and nonprivileged contact information reasonably needed for this action.

6. "Identify," for a document or communication, means state its date, type, author or sender, recipient, general subject, and present custodian without requiring disclosure of privileged substance.

7. Relevant period: [__/__/____] through [__/__/____].

No definition expands the discovery permitted by Rule 26(b).

INSTRUCTIONS

1. Answer each interrogatory separately and fully in writing under oath to the extent it is not objected to. State each objection with specificity. Rule 33(b)(3)-(4).

2. The person who makes the answers must sign them. The attorney who makes an objection must sign the objection. Rule 33(b)(5). The propounding attorney does not complete the optional respondent verification attached below.

3. If information is withheld as privileged or protected trial-preparation material, expressly make the claim and describe the withheld material sufficiently to permit assessment of the claim without revealing the protected information. Rule 26(b)(5)(A).

4. Supplement or correct an answer in a timely manner when Rule 26(e) requires it.

5. When Rule 33(d)'s business-record option applies, specify the records in enough detail for the interrogating party to locate and identify them as readily as the responding party can, and provide a reasonable opportunity for examination and copying.

6. Do not disclose protected personal identifiers, medical information, trade secrets, sealed material, or other confidential information except through an authorized procedure.

INTERROGATORIES

INTERROGATORY NO. 1:

Identify each person who has discoverable information that You may use to support a claim or defense, and briefly state the subjects of that information.

ANSWER: [________________________________]

INTERROGATORY NO. 2:

For each material allegation in paragraph [____] of [PLEADING], state whether You admit or deny it and state the principal facts supporting any denial.

ANSWER: [________________________________]

INTERROGATORY NO. 3:

For each affirmative defense or avoidance stated in Your pleading, identify the principal facts, persons with material knowledge, and documents on which You rely.

ANSWER: [________________________________]

INTERROGATORY NO. 4:

Describe Your account of the Incident or Transaction, including its date, location, participants, and material sequence of events.

ANSWER: [________________________________]

INTERROGATORY NO. 5:

Identify each nonprivileged Communication between You and [OTHER PARTY OR SPECIFIED PERSON] concerning [NARROW SUBJECT] during the relevant period.

ANSWER: [________________________________]

INTERROGATORY NO. 6:

Identify each document or category of electronically stored information that You may use to support a claim or defense concerning [NARROW SUBJECT].

ANSWER: [________________________________]

INTERROGATORY NO. 7:

If You contend that another person caused or contributed to the claimed injury, loss, or breach, identify that person and state the principal facts supporting the contention.

ANSWER: [________________________________]

INTERROGATORY NO. 8:

State each category and amount of damages, offset, or other monetary relief that You claim or dispute, and describe the method used to calculate it.

ANSWER: [________________________________]

INTERROGATORY NO. 9:

Identify each insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment or to indemnify or reimburse payments made to satisfy a judgment.

ANSWER: [________________________________]

INTERROGATORY NO. 10:

Identify each expert witness You may use at trial and state whether the witness is expected to provide a written report under Rule 26(a)(2)(B) or a summary disclosure under Rule 26(a)(2)(C).

ANSWER: [________________________________]

INTERROGATORY NO. [____]:

[INSERT CASE-SPECIFIC INTERROGATORY]

ANSWER: [________________________________]

PROPOUNDING SIGNATURE

Rule 26(g) requires the discovery request to be signed by counsel of record or by an unrepresented party. The signature certifies, after reasonable inquiry, that the request is consistent with the rules and law, is not interposed for an improper purpose, and is not unreasonable or unduly burdensome or expensive in light of the case.

Signature: [________________________________]

Name: [________________________________]

Wyoming State Bar No. (if applicable): [________________________________]

Firm or organization: [________________________________]

Address: [________________________________]

Email: [________________________________]

Telephone: [________________________________]

Attorney for / Unrepresented party: [________________________________]

Date: [__/__/____]

CERTIFICATE OF SERVICE

I certify that on [__/__/____], I served this document on the persons listed below by the method authorized for this case:

☐ Authorized electronic service

☐ U.S. mail

☐ Hand delivery

☐ Other authorized method: [________________________________]

Signature: [________________________________]

OPTIONAL RESPONDENT ANSWER VERIFICATION

STATE OF WYOMING

COUNTY OF [________________________________]

I, [________________________________], being first duly sworn, state that I am [the Responding Party / an authorized officer or agent of the Responding Party]; I have read the foregoing answers; and the answers are true and complete to the best of my knowledge, information, and belief after reasonable inquiry.

Respondent signature: [________________________________]

Printed name and capacity: [________________________________]

Date: [__/__/____]

Subscribed and sworn before me on [__/__/____].

Notarial officer signature: [________________________________]

Commission expiration, if applicable: [__/__/____]