Interrogatory Drafter

Early in discovery to establish the factual foundation and identify documents and witnesses for follow-up.

Draft interrogatories for the following case:

Case type: [e.g., breach of contract, personal injury, employment discrimination]
Your client's role: [PLAINTIFF/DEFENDANT]
Key facts to discover: [WHAT INFORMATION DO YOU NEED]
Interrogatory limit: [NUMBER — check local rules, typically 25]
Jurisdiction: [STATE/FEDERAL AND SPECIFIC COURT]
Opposing party: [INDIVIDUAL/CORPORATION]

Draft interrogatories targeting:
1. Party identification and corporate structure
2. Factual basis for claims or defenses
3. Witness identification
4. Document identification
5. Damages calculation methodology
6. Insurance coverage
7. Prior similar incidents or claims
8. Communications about the subject matter
9. Expert witness information
10. Specific factual gaps in your case theory

For each interrogatory:
- Include appropriate definitions and instructions
- Use subparts strategically (know your jurisdiction's counting rules)
- Make questions specific enough to prevent evasive answers
- Include the standard "state all facts" formulation where appropriate

Example Output

A set of 15-25 interrogatories with definitions, instructions, and targeted questions organized by topic.

Tips

• •Check local rules for interrogatory limits and subpart counting rules — they vary significantly.
• •Front-load your most important questions — if you're at the limit, the last ones matter less.
• •Pair interrogatories with document requests — ask them to identify documents, then request those documents.

Related Prompts