Interrogatories Template – Free Download 2026

Pursuant to [Rule 33 of the Federal Rules of Civil Procedure / applicable state discovery rules], Plaintiff/Defendant [____________] requests that Defendant/Plaintiff [____________] answer the following interrogatories separately, fully, and under oath within [30 / ____] days of service. These interrogatories shall be deemed continuing in nature, and you are required to supplement your answers promptly if you learn that any answer is in any material respect incomplete or incorrect. For purposes of these interrogatories, the following definitions apply: (a) "You" and "Your" mean [Responding Party] and all of its agents, employees, officers, directors, representatives, attorneys, affiliates, subsidiaries, and predecessors; (b) "Person" means any individual, corporation, partnership, limited liability company, association, governmental body, or other entity; (c) "Communication" means any oral, written, or electronic exchange of information, including letters, emails, text messages, and voicemails.

The following instructions govern your responses to these interrogatories: (a) Each interrogatory shall be answered separately and fully in writing under oath; (b) If you object to any interrogatory, state the specific grounds for objection with particularity; you must still answer any non-objectionable portion of the interrogatory; (c) If you are unable to answer any interrogatory fully after exercising due diligence to secure the information requested, so state, explaining in detail why you are unable to answer fully and setting forth whatever information or knowledge you possess regarding the subject matter of the interrogatory; (d) If any document is withheld under a claim of privilege or work product protection, identify the document in a privilege log stating the date, author, recipient(s), general subject matter, and privilege claimed; (e) Where a natural person is asked to identify a document, provide the date, author, recipient(s), title or subject, and location of each responsive document.

INTERROGATORY NO. 1: Identify all persons with knowledge of the facts alleged in the Complaint or Answer, including for each person his or her full name, current address and telephone number, employer, job title, and a brief description of the facts within that person's knowledge. INTERROGATORY NO. 2: Describe in detail all facts supporting [each affirmative defense asserted in your Answer / each element of your claims as alleged in the Complaint], including the identity of all witnesses and documents that support your position. INTERROGATORY NO. 3: Identify all documents that you intend to use as exhibits at trial or in connection with any motion, including for each document its date, author, recipient(s), title, and current location.

INTERROGATORY NO. 4: Describe all communications between you and [____________] concerning [the subject matter of this litigation], including the date, method, and substance of each communication and the identity of all participants. INTERROGATORY NO. 5: Describe in detail all damages you claim to have suffered as a result of the events alleged in the [Complaint / Counterclaim], including a computation of each category of damages, the method used to compute damages, and all documents on which each computation is based. INTERROGATORY NO. 6: Identify all expert witnesses you intend to call at trial, including for each expert: name, address, area of expertise, opinions to be expressed, and the basis and reasons for each opinion, together with a list of all publications authored by the expert in the preceding ten years and a list of all cases in which the expert has testified in the preceding four years.

VERIFICATION: I, [Name of Responding Party or Authorized Representative], declare under penalty of perjury that I have read the foregoing answers to interrogatories and that they are true and correct to the best of my knowledge, information, and belief. I am [the responding party / an officer of the responding party duly authorized to make this verification / the attorney for the responding party, making this verification because the responding party is not present in this district and the facts are principally within my knowledge]. Executed on [____________] at [City, State].