Interrogatories

A.  IDENTIFICATION & AUTHENTICATION INTERROGATORIES

The following identification and authentication interrogatories do not count against {party}’s limit of 25 interrogatories. 

INTERROGATORY 1:  Identify all insurance policies relevant to this suit.  {Ask for documents in request for production.}

INTERROGATORY 2:  Identify all invoices relevant to the contract that is the subject of this suit.  {Ask for documents in request for production.}

INTERROGATORY 3:  Identify all documents relevant to {identify specific occurrence or transaction, e.g., the Master Sales Agreement that is attached as Exhibit A to Plaintiff’s Original Petition}.

INTERROGATORY 4:  Is the {identify document, e.g., contract} attached to these interrogatories as Exhibit {letter} a true and correct copy of the original?

B.  STANDARD INTERROGATORIES

The following standard interrogatories count against {party}’s limit of 25 interrogatories. 

INTERROGATORY 1:  Identify each person answering these interrogatories, supplying information, or assisting in any way with the preparation of the answers to these interrogatories.

INTERROGATORY 2:  Identify every person who is expected to be called to testify at trial, including your experts. 

INTERROGATORY 3: Identify all discoverable, consulting experts, that is, consulting experts whose work has been reviewed by the testifying expert. For each expert named, provide the following information:

1. The expert’s name, address, and telephone number.
2. The expert’s current résumé and bibliography.
3. The facts known to the expert that relate to or form the basis of the expert’s mental impressions and opinions formed or made in connection with the case, regardless of when and how the factual information was acquired.
4. The mental impressions or opinions of the expert formed or made in connection with the case and any methods used to derive them.
5. Any bias of the expert.
6. Identify all documents and tangible things, including reports, models, or data compilations, that have been provided to, reviewed by, or prepared by or for the expert, so the documents or tangible things may properly be sought by a request for production.  {Ask for documents or tangible things in request for production.}

INTERROGATORY 4:  Identify all experts who have firsthand factual information about the case and provide a brief statement of each expert’s connection with the case.  {If the attorney believes opposing counsel has overlooked the names of experts with firsthand factual information about the case, add this question to the list of standard interrogatories.  Otherwise, omit.}  

INTERROGATORY 5:  State the legal theories and describe in general the factual bases for your {claims/defenses}.

INTERROGATORY 6:  Do you make the {legal/factual} contention that {identify specific legal or factual contention}?

INTERROGATORY 7:  Identify every person who has impeachment or rebuttal evidence and describe the evidence each person has.  If you have enough information to anticipate the use of impeachment or rebuttal evidence or witnesses, you must provide that information. {Ask for documents in request for production.} 

INTERROGATORY 8:  If you have ever been convicted of a felony or a crime involving moral turpitude, state the nature of the charge and the date and place of arrest and conviction.