Responses and objections to interrogatories

[Name]

[Address]

[Phone number]

Attorney for [responding party]

UNITED STATES DISTRICT COURT

FOR THE ___________ DISTRICT OF __________

Civil Action, File Number _________

__________________________________________

)

[Name], ) [RESPONDING

Plaintiff, ) PARTY’S]

) RESPONSES AND

v. ) OBJECTIONS

) TO [PROPOUNDING

[Name], ) PARTY’S INTERROGATORIES]

Defendant. )

__________________________________________)

PROPOUNDING PARTY: [Party Name]

RESPONDING PARTY: [Party Name]

SET NUMBER: [Number]

Pursuant to FRCP 33, [responding party] responds and answers [propounding party’s] [set number] Set of Interrogatories as follows:

GENERAL OBJECTIONS

1. [Responding party] objects to [propounding party's] instructions and definitions to the extent they seek disclosure of information protected by the attorney client privilege and/or the attorney work product doctrine. Furthermore, [responding party] objects to the interrogatories to the extent that they request information from any and all agents, attorneys, investigators, consultants, experts, and...