FORM 9 PLAINTIFF'S INTERROGATORIES—STATE COURT [CASE STYLE]

• Jurisdiction: United States

FORM 9 PLAINTIFF'S INTERROGATORIES—STATE COURT [Case Style] PLAINTIFF [NAME]'S FIRST SET OF INTERROGATORIES TO DEFENDANT [NAME]

TO: [DEFENDANT], by and through its attorneys of record, [DEFENDANT'S COUNSEL/ADDRESS]

Pursuant to Rules 192.3 and 197 of the Texas Rules of Civil Procedure, Plaintiff [NAME] ("[NAME]" or "Plaintiff") hereby requests that Defendant [NAME] ("[NAME] or "Defendant") respond to the following interrogatories ("Interrogatories").

I. INSTRUCTIONS

1. You are reminded that your written response to this First Set of Interrogatories shall state, with respect to each category of items, that inspection and other requested action will be permitted as requested, except to the extent that you object in writing to particular items or categories. Your written responses and/or objections shall be served on counsel for Plaintiff.

2. If you contend that you may partially or entirely withhold a requested response because of a rule, privilege, immunity, or other reason, for each response partially or entirely withheld, identify and state the factual basis on which you claim the privilege or immunity.

3. The definitions listed below are to be construed as broadly as possible to include the most information or documents responsive to the discovery requests propounded herein.

4. This discovery request is continuing. In the event that any information or material responsive to any Interrogatory comes to your attention, possession, custody, or control, or the attention, possession, custody, or control, or your agents, principals, employees, affiliates, subsidiaries, accountants, partners, officers, family members, directors, or attorneys subsequent to the filing of your response, you are required to furnish the additional information, responses, or material as soon as possible.

5. The terms "all" and "each" shall be construed as "all and each." In addition, the term "any" means "all and each."

6. The connectives "and" and "or" shall be construed either disjunctively or conjunctively as necessary to bring within the scope of each of the Interrogatories all responses that might otherwise be construed to be outside of their scope.

7. The term "including" shall be construed as "including, but not limited to."

8. The use of the singular form of any word includes the plural and vice versa.

9. Where it is necessary to bring within the scope of the Interrogatories information that might otherwise be construed to be outside their scope, the use of a verb in any tense...