Plaintiff's Interrogatories

• Author: Kenneth L. Dorsney
• Pages: 763-767

Plaintiff’s Interrogatories

IN THE UNITED STATES DISTRICT COURT

[Name of District]

[DISTRICT COURT CAPTION]

PLAINTIFF’S FIRST SET OF JOINT INTERROGATORIES TO DEFENDANT

Pursuant to Rule 33 and 26(e) of the Federal Rules of Civil Procedure, and the

applicable Local Rules of the United States District Court for [Name of District], plaintiff

[Name of Plaintiff] hereby requests that each of (a) Defendant; (b) Defendant [Name of

Defendant 3) (“Defendant 3”); and (c) Defendant [Name of Defendant 2] (collectively

“Defendant 2”) separately answer the following interrogatories in accordance with those

rules and the following Definitions and Instructions by serving written responses to the

offices of [Name of Counsel for Plaintiff] at [Address of Counsel for Plaintiff], on or

within thirty (30) days of service of this set of interrogatories.

DEFINITIONS

1. The term “the ’001 patent” means Plaintiff’s United States Patent No. 1.

2. The term “the ’002 patent” means Plaintiff’s United States Patent No. 2.

3. “[Active ingredient]” means [active ingredient] in any form, including

without limitation any salt thereof, or any preparation, formulation, pharmaceutical, or

product comprised of or containing [active ingredient].

4. “_____” refers to any _____ compound known to be useful as or

considered to be possibly useful as an _____.

5. “Document” means each and every writing, whether an original, a draft,

or a copy, however produced or reproduced, and each and every thing from which

information can be processed or transcribed, and includes, without limitation, all

things meeting the definitions of “writings” and “recordings” as set forth in Fed.

R. Evid. 1001. Any document without any marks such as initials, comments, or

notations of any kind is not deemed to be identical to one without such marks and is to

be produced and identified as a separate document. The term “document” is

coextensive in scope with Rule 34 of the Federal Rules of Civil Procedure.

6. “Thing” means any physical specimen or other tangible item other than

a document.

7. “Concerning” means in any way, directly or indirectly, regarding,

considering, constituting, covering, defining, describing, involving, underlying,

modifying, amending, confirming, mentioning, endorsing, recording, evidencing,

pertaining to, referring to, reflecting, relating to, representing, supporting, qualifying,

terminating, revoking, canceling, negating or having any connection with the matter

discussed.

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