Interrogatory Drafter
Early in discovery to establish the factual foundation and identify documents and witnesses for follow-up.
Interrogatories are a scarce resource. Federal Rule 33 limits each party to 25 including discrete subparts unless the court orders otherwise, and state limits vary, so every question has to earn its place by extracting information you cannot get more cheaply elsewhere. Well-drafted interrogatories lock in the opposing party's factual contentions, identify witnesses and documents, and expose the gaps in their case theory, all in answers signed under oath. Poorly drafted ones waste your limit on questions that draw objections or evasive non-answers.
Claude is a strong drafting partner here. Tell it the case type, your client's role, the specific facts you need to discover, your jurisdiction, and your numerical limit, and it produces a targeted set organized by topic, complete with definitions and instructions. It can pair each information request with a document-identification question, use contention interrogatories targeted to specific allegations, and structure subparts thoughtfully so you stay within the count that applies in your court.
Use the prompt below as a starting point. Replace the bracketed details with your case specifics, then check the result against your local rules on limits and subpart counting, which vary significantly. Claude's draft is attorney work product to refine, not legal advice; the responsible attorney must confirm scope, proportionality, and compliance before serving the set on opposing counsel.
The Prompt
Draft interrogatories for the case below. <pleadings> [PASTE THE OPERATIVE COMPLAINT AND ANSWER] </pleadings> We represent: [PLAINTIFF / DEFENDANT] Case type: [e.g., breach of contract, personal injury, employment discrimination] Key facts to discover: [WHAT INFORMATION YOU NEED] Interrogatories already served, and the limit: [NUMBER USED / LIMIT UNDER APPLICABLE RULE] Jurisdiction and court: [STATE/FEDERAL AND SPECIFIC COURT] Opposing party: [INDIVIDUAL / ENTITY] Information already covered by initial or expert disclosures: [LIST, OR "N/A"] Draft interrogatories targeting: 1. Party identification and corporate structure 2. The factual basis for specific claims or defenses 3. Witness identification 4. Document identification 5. Damages calculation methodology 6. Prior similar incidents or claims 7. Communications about the subject matter 8. Specific factual gaps in our case theory For each interrogatory: - Include appropriate definitions and instructions - Make the question specific enough to prevent evasive answers - Use contention interrogatories sparingly, targeted to a specific allegation (for example, "state the principal facts supporting your contention in ¶ __") - Explain how each subpart would likely count under [APPLICABLE RULE], and keep the set within the remaining limit - Do not spend interrogatories on information already required by initial or expert disclosures Cite pleading paragraphs only as they appear in <pleadings>. If something I need is missing or ambiguous, say so instead of assuming. Do not invent facts, citations, or quotations; mark anything you are unsure of [VERIFY]. This is a draft for attorney review.
Example Output
A targeted set of interrogatories with definitions, instructions, and questions organized by topic, with notes on how subparts are likely to count against your limit.
Illustrative example — names, figures, and facts are fictional.
PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT
Case: Okafor v. Dellwood Staffing, Inc.
U.S. District Court, N.D. Ill. | Case No. 26-cv-03914
DEFINITIONS
"YOU"/"DEFENDANT" means Dellwood Staffing, Inc., its officers,
employees, and agents. "IDENTIFY" (person) means state full name,
last known address, and employer. "DOCUMENT" has the meaning in
Fed. R. Civ. P. 34(a).
INSTRUCTIONS
These interrogatories are continuing under Rule 26(e). If You
withhold any response on a claim of privilege, state the basis.
INTERROGATORIES
1. IDENTIFY each person who participated in the decision to
terminate Plaintiff's assignment, and state each person's role
in that decision.
2. State the principal facts supporting Your contention in
Paragraph 12 of Your Answer that Plaintiff's termination was
for a legitimate, non-retaliatory reason, and IDENTIFY the
principal DOCUMENTS supporting that contention.
3. IDENTIFY each complaint of discrimination or retaliation made
against You by any worker assigned to the Riverside facility
from January 1, 2023 to the present.
4. State the methodology used to calculate any back-pay or
benefits owed to Plaintiff, including each variable and figure
relied upon.
5. IDENTIFY all communications between any DELLWOOD manager and the
client employer concerning Plaintiff, and IDENTIFY the DOCUMENTS
reflecting those communications.
[Continues, 14 interrogatories total, within the applicable limit
including discrete subparts. Expert and insurance information is
omitted because initial and expert disclosures already require it.]Tips
- •Check local rules for interrogatory limits and subpart counting rules; they vary significantly.
- •Front-load your most important questions in case you reach the limit.
- •Don't spend interrogatories on information already required by initial or expert disclosures.
- •Pair interrogatories with document requests: ask them to identify documents, then request those documents.
- •Treat the output as a draft for attorney review; verify every citation, quotation, date and figure against the source before relying on it.
Frequently Asked Questions
When in the case should I serve interrogatories drafted with this prompt?
Typically early in discovery, once the pleadings frame the issues, to establish the factual foundation and identify witnesses and documents for follow-up depositions and requests. The prompt asks for your key facts to discover and your case theory so the set targets the specific gaps you need to fill, rather than generic boilerplate that opposing counsel can brush aside.
Can I serve Claude's interrogatories as drafted?
No. Review each question before serving. Confirm the set complies with your court's limit and subpart-counting rules, tighten any question vague enough to invite an evasion objection, and verify the definitions and instructions match local practice. AI does not know your judge's standing orders. The attorney is responsible for scope, proportionality, and Rule 26 compliance of the served set.
How do I get the most effective interrogatories?
Front-load your most important questions in case you reach the limit, and tell Claude exactly what factual gaps exist in your case theory. Ask it to pair information requests with document-identification questions, use contention interrogatories tied to specific allegations, and flag where subparts may count separately under your rules so you can manage the count deliberately.
What confidentiality precautions apply when drafting discovery with AI?
Your discovery strategy and the case facts you input are protected work product and client information under Model Rule 1.6. ABA Formal Opinion 512 directs lawyers to vet an AI tool's data practices and obtain client consent where appropriate. Use a business deployment with no-training terms, and avoid entering privileged strategic analysis or client identifiers into a consumer chatbot.
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