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Discovery Interrogatories from Defendant to Plaintiff with Production Requests

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Defendant's First Set of Interrogatories Propounded to the Plaintiff With Request for Production

IN THE DISTRICT COURT FOR

PARISH, STATE OF LOUISIANA

, Petitioner/Plaintiff

Vs.

, Respondent/Defendant

DEFENDANT'S FIRST SET OF INTERROGATORIES PROPOUNDED TO THE PLAINTIFF WITH REQUEST FOR PRODUCTION

CASE NO.

COMES NOW ("Defendant") and propounds the following interrogatories to ("Plaintiff") pursuant to Louisiana Rules, and other applicable provisions of said Rules, and gives notice that each and every interrogatory or section thereof is to be answered separately, in writing, under oath of the aforesaid Plaintiff within the legal number of days of the date of service hereof, and further gives notice that these interrogatories and request for production of documents and things are deemed to be continuing, and, that if different or additional information is received by Plaintiff after answers hereto are submitted and filed, same is to be provided to this Defendant in writing. Production requests are also made pursuant to the rules of the State of Louisiana. Defendant requests that Production of documents be made on the same date as the date Answers to Interrogatories are due and shall be made to Defendant at the following address:

INTERROGATORY NO. 1

State your full name, social security number, date of birth, residence address, and telephone number.

INTERROGATORY NO. 2

Please attach to your answer to these interrogatories copies of your income tax returns and W-2 forms for the past three years.

INTERROGATORY NO. 4

State your total income to date since , and attach to your answers copies of your last five paycheck stubs.

INTERROGATORY NO. 5

List all assets presently owned by you. Give a complete and detailed listing. For each asset, give its nature, description, location, date of acquisition, present market value, and the name and address of any person that you hold same with jointly.

INTERROGATORY NO. 6

List the name, place of employment and telephone number of any person or persons who are presently residing at the address which you listed as your residence in your answer to Interrogatory No. 1.

INTERROGATORY NO. 7

If you rent the place in which you live, give the name of your landlord, his or her address and telephone number.

INTERROGATORY NO. 8

Outline in detail your monthly living expenses.

INTERROGATORY NO. 9

List all other income received by you other than from your employment, stating the source and the amount.

INTERROGATORY NO. 10

If you claim to have grounds for divorce against the Defendant, please state all circumstances, facts, and events, upon which you base such grounds.

INTERROGATORY NO. 11

What safety deposit boxes do you currently maintain whether alone or jointly held? For each box, state the name and address of the bank, the box number, the name in which said box is maintained, the name and address of each and every person having access thereto, the contents of each box, and the date each box was acquired.

INTERROGATORY NO. 12

What bank accounts, if any, do you presently maintain, whether alone or jointly held? For each account, state whether active, inactive or closed, the style of the account, the name of the bank or banks, the name and address of each and every person authorized to make withdrawals therefrom, the account number, and whether checking or savings.

INTERROGATORY NO. 13

Do third parties hold any property in trust for you or for your benefit? If so, give full and complete particulars, including the name and address of said persons and exact descriptions and locations of property.

INTERROGATORY NO. 14

Have you ever been arrested? If so, for each occasion, state the date of the arrest, the county and state in which the arrest occurred, and the reason for such arrest.

INTERROGATORY NO. 15

Have you ever received psychiatric treatment? If so, state the physician administering same, his address and telephone number, and the date or dates of the treatment.

INTERROGATORY NO. 16

Are you taking any drugs, and the amount of money you spend each month for said drugs.

INTERROGATORY NO. 17

Do you use any type of drugs which are not prescribed by a physician (i.e., marijuana, heroin, cocaine)? If so, state the type of drug or drugs which you use, the place in which you exercise such use, when you began using said drug or drugs, and the amount of money you spend each month for said drugs.

INTERROGATORY NO. 18

Do you consume alcoholic beverages on a regular basis? If so, state the type of alcoholic beverage which you consume, and the amount of money you spend each month on said alcoholic beverages.

INTERROGATORY NO. 19

Are you addicted to alcohol or drugs of any kind? If so, specify what it is you are addicted to and when you became addicted to same.

INTERROGATORY NO. 20

Have you ever had sexual relations with anyone other spouse during the course of your marriage? If so, name and address of each individual, and the time of each sexual encounter.

INTERROGATORY NO. 21

State whether or not you have provided any banks or other lending institutions with financial statements during the past 24 months. For each such occurrence, state the names and addresses of the banks or lending institutions, and the date said financial statement was provided.

INTERROGATORY NO. 22

For each person you shall call as a witness at the trial of this case, please state: the witness's name and address, whether employed by you, and the subject matter to which the witness shall testify. Prior to trial, please supplement your answer to this interrogatory.

INTERROGATORY NO. 23

For each person you allege to be an occurrence witness of any of the things and matters sought to be proved by you at the trial of this case, please state: the witness's name and address, whether employed by you, and the subject matter to which the witness shall testify. Prior to trial, please supplement your answers to this interrogatory.

INTERROGATORY NO. 24

For each person whom you expect to call as an expert witness at the trial, providing his name, address and telephone number, please state:

a. The subject matter in which identified is expected to testify.

b. The substance of the facts and which each expert is expected to testify.

c. Give a summary of the grounds for each person set out above.

d. State the educational background, educational training, and experience of each person above which qualifies him as an expert, and identify the field of such expertise.

INTERROGATORY NO. 25

For each document or other item you shall offer as an exhibit at the trial of this case, please state: the title or name of the document, date of the document and purpose for which it will be used as an exhibit.

INTERROGATORY NO. 26

State the names and addresses of all persons involved in the answering of these interrogatories.

INTERROGATORY NO. 27

Have you, as the Defendant in this case, read the answers to each and every one of the above interrogatories and requests for production of documents and things, and do you state that the answers thereto are true, complete, responsive and correct?

INTERROGATORY NO. 28

If, at any time between this date and the date of the trial of this cause, you come into possession of information which, if such information were known to you, would properly have to be disclosed in the answers to these interrogatories or requests for production of documents and things, or any of them, will you disclose such newly discovered information, if any, to Defendant within fifteen days after such information comes into your possession or prior to the trial, whichever is first?

Respectfully submitted,

________________________________

Signature of Defendant

NAME:

CERTIFICATE OF SERVICE

I, the undersigned, , Defendant, do hereby certify that I have this day mailed, by United States mail, postage prepaid, a true and correct copy of the above and foregoing Defendant's First Set of Interrogatories to Plaintiff at:

Name of Plaintiff

DATED, this the day of , 20.

________________________________
Signature of Defendant

NOTICE OF SERVICE OF DISCOVERY

IN THE DISTRICT COURT FOR

COUNTY, STATE OF LOUISIANA

, Petitioner/Plaintiff

Vs.

, Respondent/Defendant

NOTICE OF SERVICE OF DISCOVERY

TO: All Counsel of Record:

Notice is hereby given that Defendants have this date served in the above entitled action:

DEFENDANT'S FIRST SET OF INTERROGATORIES PROPOUNDED TO THE PLAINTIFF WITH REQUEST FOR PRODUCTION

The undersigned retains the originals of the above papers as custodian thereof pursuant to Court Rules.

DATED:

Respectfully Submitted,

By:

Signature of Defendant

CERTIFICATE OF SERVICE

I, , Defendant in the above referenced civil action, do hereby certify that I have this day caused to be delivered, via United States Postal Service, first class postage prepaid, a true and correct copy of the above and foregoing document to:

Plaintiff's Name

THIS the day of , 20.

____________________________________
Signature

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What this set of discovery requests is and when it’s used

The Discovery Interrogatories from Defendant to Plaintiff with Production Requests is a combined litigation tool that asks numbered written questions (interrogatories) and requests responsive documents and electronically stored information. It narrows disputed facts, identifies witnesses and evidence, and initiates formal document collection under applicable civil procedure rules. Typical use follows complaint and initial disclosures; answers must be verified and accompanied by a document production that references specific requests and any privilege logs.

Why defendants serve interrogatories and production requests

These combined requests focus the factual record, compel documents and narrative responses, and reduce surprise at depositions or trial. Properly drafted discovery clarifies issues, preserves evidence, and supports later motions or settlement discussions.

Why defendants serve interrogatories and production requests

Who prepares and responds to these discovery requests

Typical users include litigation attorneys and their support staff who draft, serve, and track responses under court rules.

  • Defense counsel and litigation teams who draft targeted interrogatories and requests for production.
  • Plaintiff’s counsel and clients who assemble responsive documents and prepare verified answers.
  • Paralegals and litigation support who organize ESI, Bates-stamp files, and maintain privilege logs.

Coordination between counsel, IT, and records custodians ensures timely, complete, and appropriately redacted productions.

Typical signers and submitters

Defense Counsel

Partner or associate overseeing discovery who signs certificates of service and coordinates production. Responsible for meeting-and-confer, motion practice, and ensuring interrogatories comply with scope and relevance limits.

Plaintiff Representative

Named plaintiff or authorized corporate officer who verifies factual answers and signs the verification clause; must attest to the completeness of searched records and the accuracy of responses under penalty of perjury.

Core components to include in a professional discovery package

A complete set combines a caption, clear definitions, numbered interrogatories, document requests, instructions, and a verification block to create an enforceable discovery production.

Case Caption

Court, parties, case number and judge identified so responses are unambiguously tied to the matter and properly served.

Definitions

Clear, narrowly tailored definitions (e.g., 'document', 'communication', date ranges) reduce dispute and limit objections.

Interrogatories

Numbered written questions seeking factual narrative, dates, identities, and exhibits — keep each interrogatory to a single subject where practical.

Production Requests

Specific requests for documents and ESI with date ranges, custodians, and preferred formats (PDF, native, load files) to streamline review.

Instructions

Instructions about search methodology, ESI protocols, privilege assertions, and Bates-stamping expectations prevent later disputes.

Verification

Signature block where the responding party verifies answers under penalty of perjury and identifies the custodian responsible for searches.

Required form elements and metadata

Case Caption: Court and case number
Party Information: Full legal names
Interrogatory Number: Sequential identifiers
Response Text: Answer or objection
Production Identifier: Bates range or exhibit label
Verification Block: Signature and date

Step-by-step: drafting and serving the package

Follow a disciplined sequence to draft, approve, serve, and track interrogatories and production demands to meet procedural deadlines and preserve privileges.

  • 01
    Gather case facts: Identify issues, dates, witnesses, and custodians first.
  • 02
    Draft questions: Compose concise, single-subject interrogatories with defined terms.
  • 03
    Specify production: List document categories, formats, and date ranges clearly.
  • 04
    Serve and track: Serve per rules and maintain certificate of service.

How to customize and complete these requests online

Configure a digital workflow that pre-fills case fields, applies authentication, and assigns a reviewer to manage privilege redactions.

Field Configuration
Document upload PDF or Word DOCX; retain original metadata
Pre-fill party names Use smart fields or Magic detection to reduce errors
Authentication Email link plus optional SMS or KBA
Attach exhibits Number exhibits; include a contents index

Where to send responses and productions

Serve responses to the requesting party and retain proof; file with the court only when required by local rules or by motion.

  • Serve opposing counsel: Email, e-service portal, or in-hand per local rules
  • File if required: File motion or response in court per local practice
  • Deliver productions: Use secure file transfer or production platform
  • Preserve proof: Keep certificates of service and delivery logs

Digital signing, file formats, and integration considerations

Choose a platform that supports PDF and DOCX, preserves metadata, and records an audit trail for each signer and action.

  • Supported formats: PDF, Word DOCX, native ESI exports
  • Authentication: Email links, SMS codes, and optional advanced methods
  • Integrations: Connectors for cloud storage and matter management

Secure storage, audit trails, and integrations with document management systems reduce manual handling and help satisfy court discovery orders while preserving chain-of-custody records.

Key timing rules and practical deadlines

Timing varies by federal or state procedure; plan for standard windows and provide buffer days for meet-and-confer and production tasks.

Response window:

Typically 30 days from service under many civil rules

Production timing:

Document production usually due with or shortly after answers

Extension practice:

Parties often stipulate short extensions in complex cases

Compel process:

File motion after meet-and-confer if responses are deficient

Preservation duty:

Duty to preserve evidence arises immediately on notice

Common drafting and production pitfalls to avoid

  • Overbroad request language that invites boilerplate objections and motion practice instead of usable evidence.
  • Failing to search relevant custodians and data sources, producing incomplete ESI or missing key documents.
  • Late service or missed deadlines that trigger sanctions or motion-to-compel exposure.
  • Poor privilege logs or redactions that lead to clawback disputes and admissibility fights.

Consequences of improper discovery responses

Court sanctions: Monetary or evidentiary penalties
Motion to compel: Judge may order production
Objection waiver: Untimely objections can be forfeited
Fee shifting: Adverse party costs may be assessed
Evidence exclusion: Suppressed evidence at trial
Contempt: Possible contempt for willful noncompliance

Real-world examples of digital discovery and signing in practice

Organizations streamline production and authentication by combining secure eSignature with ESI export and audit trails.

Tech Data — Bob Dutkowsky

Tech Data implemented digital workflows for discovery and client approvals to reduce turnaround time.

  • The result was faster document exchange.
  • Bob Dutkowsky reported improved internal and external customer service while accelerating speed to revenue and reducing manual handling of signed materials.

Fertility Centers — John Butler

A healthcare provider used secure eSignature with audit trails for patient consents and records.

  • This kept PHI controlled during remote workflows.
  • John Butler highlighted responsive support and API integrations that helped the organization maintain compliance across mobile and offline signing scenarios.

Typical eSignature pricing and capabilities for discovery workflows

Platform pricing and features affect volume costs, HIPAA support, and bulk sending; compare starting prices, trial availability, and envelope or invite limits.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Trial 7-day free trial Varies by vendor Varies by vendor Varies by vendor Varies by vendor
Bulk Send Yes (Business Premium) Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes (BAA available) Yes Yes No No
Envelope Cap No cap 100 envelopes/user/year Varies by plan Varies by plan Varies by plan

Frequently asked questions about preparing and serving these discovery requests

Answers to common procedural and technical questions that arise when drafting, serving, and responding to interrogatories and production requests.


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