Legal Interrogatories Form

Legal Interrogatories Form

Plaintiff Name:   v.   Defendant Name:

Case Number:   Court:   Date of Service:

RECITALS

WHEREAS, Plaintiff alleges that the facts and circumstances set forth in the complaint gave rise to legal claims against Defendant and seeks discovery relevant to those claims; and

WHEREAS, Defendant is the responding party in these interrogatories and is obligated to answer under oath to the extent required by the applicable rules of civil procedure; and

WHEREAS, the parties will use these interrogatories to obtain information, admissions, and documents relevant to the claims and defenses asserted in this action.

NOW, THEREFORE, the responding party is requested to answer the following interrogatories fully, separately, and in writing under oath within the time permitted by applicable rules.

INSTRUCTIONS AND DEFINITIONS

1. Definitions: The terms "you" or "your" mean the responding party and, where applicable, any agent, predecessor, or person acting on the responding party's behalf. The term "document" includes, without limitation, any writing, record, correspondence, memorandum, photograph, electronic file, or other tangible thing within the meaning of the rules of civil procedure.

2. Scope and Continuing Obligation: These interrogatories are continuing. If, after serving answers, the responding party obtains additional information responsive to any interrogatory, supplemental answers shall be served promptly in accordance with applicable rules.

3. Form of Answer: If an interrogatory cannot be answered completely, answer to the extent possible and state the reason for your inability to answer the remainder, specifying any known information and sources that may lead to the discovery of responsive information.

INTERROGATORIES

INSTRUCTION: Provide complete factual answers. For each interrogatory, state the name, address, and telephone number of each person with knowledge of the facts responsive to the interrogatory and identify documents that substantiate the answer.

1. State your full legal name, business address, and any other names by which you have been known in the past ten years.
2. Describe, in chronological order, all facts known to you that relate to the events alleged in the complaint, identifying dates, locations, and the persons involved.
3. Identify each document that supports your defenses or refutes any allegation in the complaint; for each document provide the custodian, date, and a brief description.
4. State with specificity each witness you intend to rely upon and summarize the substance of their expected testimony.
5. Describe all communications between you and the opposing party or representatives of the opposing party relating to the subject matter of this action, including dates, participants, and communication medium.
6. Itemize any damages you claim or deny, providing computation, supporting methodology, and identification of documents used to calculate the amounts.
7. Identify any expert witnesses you have retained or consulted, their qualifications, subject of expected testimony, and provide a summary of their opinions.
8. State whether you assert any affirmative defenses and, for each defense, provide the factual basis and identify documents supporting the defense.
9. Describe any insurance policies that may provide coverage for the claims in this action, including insurer name, policy number, coverage limits, and the nature of coverage.
10. Identify any person who conducted an investigation, inspection, or test relating to the events alleged and describe the findings, dates, and location of any resulting reports.

CLAIM OF PRIVILEGE

If you assert that any response or portion thereof is privileged or otherwise protected from disclosure, state the basis for the claim of privilege, the precise nature of the privilege claimed, the author and recipient of the withheld material, the date, and a brief description sufficient to assess the claim.

VERIFICATION

I, the undersigned, declare under penalty of perjury under the laws of the State of that the foregoing answers are true and correct to the best of my knowledge, information, and belief.

SERVICE DECLARATION

NOTICES

All notices or correspondence concerning these interrogatories shall be sent to the addresses stated below.

MISCELLANEOUS PROVISIONS

Amendments: These interrogatories may be amended or supplemented only by written agreement of the parties or by court order. Any amendment or supplement shall specify the interrogatory being amended and the amended answer.

Waiver: Failure to assert a claim or objection in a timely manner may constitute a waiver of that claim or objection to the extent permitted by governing law and rules of procedure.

Governing Law: These interrogatories and any disputes concerning their scope or responses shall be governed by the laws of the State of .

Entire Agreement: These interrogatories constitute the complete statement of the discovery requested herein and supersede any prior written discovery requests that are inconsistent with these interrogatories.

Severability: If any provision of these interrogatories is held invalid or unenforceable, the remaining provisions shall remain in full force and effect.

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