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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

Name of Defendant

Address

City, State, Zip

Phone

IN THE CIRCUIT COURT FOR

COUNTY, STATE OF WISCONSIN

,
,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 Wisconsin 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 Wisconsin. 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.

Upload/describe attached documents:

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

Address

DATED, this the day of , 20.

________________________________

Signature of Defendant

NOTICE OF SERVICE OF DISCOVERY

Name of Defendant

Address

City, State, Zip

Phone

IN THE CIRCUIT COURT FOR

COUNTY, STATE OF WISCONSIN

,
,Petitioner/Plaintiff

Vs.

,
,Respondent/Defendant

NOTICE OF SERVICE OF DISCOVERY

CASE NO.

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

Address

THIS the day of , 20.

____________________________________

Signature

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What this set of interrogatories and production requests is

Discovery Interrogatories from Defendant to Plaintiff with Production Requests are written questions and requests served under the Federal Rules of Civil Procedure (see Rules 33 and 34) that require the plaintiff to state factual answers and to produce responsive documents or electronically stored information. They formalize fact-finding before trial, define the scope and time period of relevant evidence, and create a record that can be used for motions, depositions, or trial. Properly drafted, served, and preserved interrogatories and production requests reduce surprises, focus depositions, and support discovery motions if responses are incomplete or evasive.

Why defendants use interrogatories with production requests

These combined discovery tools compel sworn factual answers and documentary production, narrow disputed facts, and can expose weaknesses in a plaintiff's claims. They cost less than depositions and often speed case evaluation.

Why defendants use interrogatories with production requests

Who typically prepares and serves these discovery requests

Defense counsel and litigation teams commonly prepare interrogatories with production requests to obtain admissions, documents, and the plaintiff’s factual account before depositions or motions.

  • Defense attorneys or litigation partners responsible for case strategy and discovery decisions.
  • In-house corporate counsel coordinating document preservation and custodian interviews.
  • Paralegals and litigation support staff who assemble definitions, document lists, and service copies.

Paralegals and litigation support staff usually format, review, and serve the package under counsel supervision; pro se defendants may also prepare simplified versions following local rules.

Step-by-step process to draft, approve, and serve these requests

Follow a consistent workflow: define scope, draft precise questions, attach production requests, review for privilege and proportionality, then serve according to court and local rules.

  • 01
    Define scope: Identify relevant timeframes, custodians, and subject areas to avoid overbreadth.
  • 02
    Draft questions: Use clear, numbered interrogatories and cross-reference defined terms.
  • 03
    List documents: Draft production requests with specific categories and format instructions.
  • 04
    Serve and track: Serve per local rules, confirm service, and log deadlines.

Core components to include in a professional discovery package

A complete set of interrogatories with production requests should combine clear definitions, precise questions, document categories, service instructions, signature verification, and privilege instructions.

Caption and service

Complete caption and service block identify the court, parties, and where service is directed; include counsel contact information and methods of service permitted by local rule.

Definitions and instructions

A definitions section sets meanings for repeated terms and instructs the responding party on how to interpret date ranges, custodians, and document types, reducing objections about vagueness.

Interrogatory schedule

Numbered interrogatories should be concise, avoid compound subparts, and indicate whether answers must be verified under oath, as required by Rule 33(b)(3).

Production requests

Organize document requests by category, specify date ranges and custodians, and state preferred production format (e.g., native files, searchable PDF, load file for ESI).

Privilege and confidentiality

Include a procedure for asserting privilege, log requirements, and proposed confidentiality designations to streamline meet-and-confer discussions.

Verification and signature

Provide a verification form where required and a signature block for counsel certifying service and compliance with local rules and meet-and-confer obligations.

Required identifying details and metadata to include

Case caption: Court name; plaintiff v. defendant
Docket number: Exact case number
Party contact: Counsel name and address
Definitions: Defined terms and timeframes
Interrogatory numbering: Sequential numbers for answers
Production format: Native, PDF, or TIFF

How to set up an online workflow for preparing and serving discovery

Configure a repeatable online workflow that enforces template fields, supports attachments, and captures service evidence for the case file.

Field Configuration
Template selection Choose a discovery template with caption and definitions prefilled
Auto-numbering Enable sequential interrogatory numbering to prevent omissions
Attachment handling Allow multiple exhibits and specify file format rules
Audit log Record edits, uploads, and service timestamps

Digital signing and secure delivery setup

Use a platform that supports secure document storage, detailed audit logs, and optional advanced authentication for served discovery documents.

  • Encryption: TLS in transit, AES-256 at rest
  • Audit trail: Time-stamped IP and action log
  • Authenticator options: Email, SMS code, or third-party KBA

Where to send and how to file completed discovery documents

Serve discovery to opposing counsel per local rules, preserve a signed proof of service, and file only if required by the court or as an attachment to a discovery motion.

  • Service to counsel: Email or e-service using agreed method; confirm receipt
  • Court filings: File only if required for a motion or local rule
  • Certificate of service: Include a sworn certificate establishing date and method
  • Preservation: Retain originals and platform audit logs

Typical deadlines and required response times

Be aware of federal and local timelines: responses and productions are time-sensitive under the Federal Rules and local civil procedure.

Interrogatory response time:

Usually 30 days per FRCP 33(b)(2)

Production response time:

Typically 30 days under FRCP 34; timing may differ by agreement

Meet-and-confer deadlines:

Local rules often require prompt conference before motions

Extension practice:

Parties may stipulate extensions; seek court approval if needed

Preservation duty:

Preserve relevant ESI upon reasonable anticipation of litigation

Key litigation milestones tied to discovery timing

Track milestones from service through motion practice to ensure compliance and to support strategic timing for depositions and law-and-motion.

01

Serve Requests

Draft and serve interrogatories and production requests

02

Receive Responses

Opposing party serves verified answers and production

03

Meet and Confer

Address deficiencies and negotiate search terms

04

File Motions

Move to compel or for sanctions if unresolved

Common drafting and service mistakes to avoid

  • Overbroad date ranges inviting proportionality objections and costly ESI searches.
  • Compound or ambiguous interrogatories that prompt objections rather than substantive responses.
  • Failing to meet-and-confer obligations before filing a motion to compel, risking sanctions.
  • Neglecting to specify production format, causing delay and unnecessary reformatting costs.

Risks and potential consequences of deficient discovery practice

Spoliation risk: Court sanctions or adverse inference
Waiver of objections: Failure to timely object may waive rights
Sanctions: Monetary sanctions or cost shifting
Motion denial: Court may deny relief if procedures ignored
Privilege exposure: Inadvertent disclosure without clawback
Default risk: Extreme noncompliance can lead to dispositive consequences

How interrogatories compare with production-only requests

Interrogatories and production requests overlap but serve distinct functions — one seeks sworn answers, the other seeks documents or ESI.

Criteria Interrogatories Production Requests
Primary purpose obtain sworn facts obtain documents / esi
Form of response verified written answers document production
Typical timeline 30 days standard 30 days standard
Use in motion practice for admissions and detail for evidentiary document support

eSignature vendor comparison for discovery signing and secure delivery

Platform pricing, bulk send, audit trail, and HIPAA support vary; signNow is listed first per supplier comparison conventions.

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 plan Varies by plan Varies by plan Varies by plan
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No
Envelope Cap No cap 100 envelopes/user/year Varies Varies Varies

Example scenarios using defendant interrogatories with production requests

Real-world examples show how these discovery tools clarify issues and often shorten litigation timelines.

Commercial Contract Dispute

A defendant used targeted interrogatories to narrow relevant contract terms and identify key custodians

  • The production request sought emails from two custodians over six months
  • After receiving specific documents and admissions, the case settled before costly depositions and trial preparation.

Personal Injury Claim

Defense counsel requested medical billing records and witness statements with narrow date ranges

  • Interrogatories asked for prior injury history and treatment providers
  • The combined responses exposed inconsistent treatment histories, enabling an effective motion for partial summary judgment.

Common questions about using interrogatories with production requests

Answers to frequently asked questions about timing, e-signatures, objections, privilege, and amendments to discovery requests.


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