Interrogatories

[Name

[Address]

[Phone number]

Attorney for [propounding party]

UNITED STATES DISTRICT COURT

FOR THE ___________ DISTRICT OF __________

Civil Action, File Number _________

__________________________________________

)

[Name], ) [PROPOUNDING

Plaintiff, ) PARTY’S]

) INTERROGATORIES

v. ) TO

) [RESPONDING

[Name], ) PARTY]

Defendant. )

__________________________________________)

PROPOUNDING PARTY: [Party Name]

RESPONDING PARTY: [Party Name]

SET NUMBER: [Number]

Pursuant to FRCP 33, [propounding party] hereby requests the [responding party] to answer the following interrogatories fully and separately in writing and under oath within 30 days of service.

DEFINITIONS

[Define any terms used in your interrogatories that need to be defined with precision to prevent confusion, promote clarity and keep the responding party from wiggling out of responses by feigning misunderstanding, e.g.,:]

1. “You” and “your” refer to [responding party] and each of its affiliates, attorneys, accountants, divisions, subdivisions, predecessors, directors, officers, employees, agents, representatives and all persons acting or purporting to act on its behalf.

   The backs of pages thereto, each non identical copy is a separate document. “Document” shall also include electronic mail, tapes, disks, diskettes, data cells, tape back ups, drums, printouts and all other data compilations from which information can be obtained (translated, if necessary, by you through...