Interrogatories - Contract/Accounting Related Actions

Breach of Written Contract

[Plaintiff to Defendant]

1. Did you execute [enter into, or ratify] a contract between yourself and the Plaintiff dated _____, 20 __ , a copy of which is attached as Exhibit “A” to the Plaintiff’s Complaint?¹ If so, state whether or not you complied with each and every provision of that Contract, and if you failed to do so, then please identify by Paragraph Number [or letter], the provision that you breached and state the reason for the failure or breach.

2. For each affirmative defense that you are asserting, please identify the defense and specifically set forth all of the facts and evidence that you intend to use to support such defense; also, for each such defense, identify all documents (by title, date, author, custodian and a summarization of contents) that you intend to use to support the defense, and all persons who have knowledge of facts supporting the defense; such persons should be identified by name, address, title, relation to the parties herein and a description of the information that they are to present.

   [Defendant to Plaintiff]

1. Set forth and describe specifically and in detail, each and every breach of the subject contract that you claim the Defendant committed; and with respect to each breach, set forth the date that you claim the breach occurred, the conduct or lack thereof that contributed to the breach, and the particular paragraph and clause that...