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[Although rule changes may affect/limit use of the following federal discovery requests (prepared by a pro se) which include interrogs, documents, admissions, they should still provide useful ideas. - staff]

1 INTERROGATORIES

XXXXXXXXX )
PLAINTIFF, ) PLAINTIFF'S FIRST SET OF
) INTERROGATORIES TO
v. )
)
XXXXXXXXX )
DEFENDANTS. )
_________________________________)

PROPOUNDING PARTY: Plaintiff XX

RESPONDING PARTY: Defendant xx.

SET: One.

Plaintiff requests you answer the following "Interrogatories" in conformity with Federal Rule of Civil Procedure 33.

DEFINITIONS AND INSTRUCTIONS

As used in this discovery request, the fully CAPITALIZED terms have the following meanings:

ADDRESS means a mailing address and a street address which includes a room, suite or apt number, city, state and zip code.

COMMUNICATION and COMMUNICATE includes any instance in which information is conveyed by or between one or more PERSONS by written and oral contacts of any kind including telephone calls, transmission of DOCUMENTS by any means, and face-to-face meetings.

COMPLAINT means the "Complaint for Damages..." filed July 15, 20 , in the above referenced Case No. CV-F-9 .

DEFENDANT means any PERSON so named in the COMPLAINT.

DOCUMENT means all writings, recordings and photographs, as defined in Rule 1001 of the Federal Rules of Evidence, in YOUR possession, custody or control or known by YOU to exist.

IDENTIFY or IDENTITY, referring to a natural PERSON includes, and means to state:
a. Their full name;
b. Their last known residential ADDRESS and telephone number;
c. Their last known occupation, title and employer;
d. Their last known business ADDRESS and telephone number;
e. Their relationship with YOU.

IDENTIFY or IDENTITY, referring to any other PERSON includes, and means to state:
a. Its full name;
b. Its legal form and place of organization;
c. The last known ADDRESS and telephone number of its principal office;
d. Its primary business or activity.

IDENTIFY or IDENTITY, referring to a DOCUMENT or thing includes, and means to:
a. State its title, number or other distinguishing feature;
b. Describe its physical form and how many pages it contains;
c. State the date it bears;
d. State the date it was prepared;
e. Describe its subject matter and substance in detail;
f. IDENTIFY the last known LOCATION and custodian of it and of its original;
g. IDENTIFY any PERSON who prepared it;
h. IDENTIFY any PERSON who transmitted it;
i. IDENTIFY any PERSON who received it;
j. IDENTIFY any PERSON who read it;
k. Describe which portions of it YOU read and relied upon.

IDENTIFY or IDENTITY, referring to a COMMUNICATION includes and means to:
a. State the date, time and LOCATION it occurred;
b. State its subject matter and substance;
c. State whether it was in written, oral, documentary, telephonic, face-to-face, or other form;
d. IDENTIFY any PERSON who was involved with or witnessed it and describe in detail their participation including the substance of what each said, did or communicated.
e. IDENTIFY any DOCUMENT or COMMUNICATION relating to it.

IDENTIFY or IDENTITY, referring to an act, event, occurrence, or fact includes and means to:
a. Provide a detailed description of it;
b. IDENTIFY any PERSON who was present during, participated in, or witnessed it;
c. State the date, time and LOCATION of it;
d. IDENTIFY any DOCUMENT or COMMUNICATION relating to it.

IDENTIFY or IDENTITY, referring to a POLICY, practice or custom includes and means to:
a. Provide a detailed description of it;
b. State the dates it was formulated and adopted;
c. IDENTIFY each PERSON who formulated it;
d. IDENTIFY each PERSON responsible for enforcing it;
e. IDENTIFY each PERSON who in the regular course of their duties has knowledge of it;
f. IDENTIFY any DOCUMENT or COMMUNICATION relating to it.

LOCATE or LOCATION means to provide a detailed physical description of exactly where a PERSON, object or event can be found or occurred, including, but not limited to, an ADDRESS.

PERSON means a natural person as well as all types of business, fictitious, governmental and public entities.

PLAINTIFF means XX, his agents and anyone else acting on his behalf.

POLICY means a rule, procedure or directive, formal or informal, written or unwritten, and includes each common practice, custom and understanding of course of conduct recognized and accepted as such by YOU or by PERSONS subject to it.

WRONGFUL ACTS means the improper, tortious, or illegal actions or conduct which the COMPLAINT alleges harmed PLAINTIFF, but this special meaning applies only to the factually identical actions or conduct alleged in the COMPLAINT and to no others.

YOU and YOUR means the above-named "Responding Party" and includes your agents, employees, attorneys, advisors, and any other PERSON acting on your behalf.

When construing any words or terms used herein, unless otherwise indicated:
a. The singular includes the plural and vice versa;
b. Masculine, feminine or neuter gender include each other;
c. Past, present or future tense include the other tenses;
d. The disjunctive includes the conjunctive and vice versa;
e. "and" includes "or" and vice versa;
f. "any" includes "all," "each" and "every" and vice versa;
g. "refer" includes "relate" and "concern" and vice versa.

Unless otherwise stated, the period for which these requests seek information is from ,20 to the date of your response.

INTERROGATORIES

INTERROGATORY #1:
INTERROGATORY #2:
INTERROGATORY #3:
INTERROGATORY #4:
INTERROGATORY #5:

Dated: , 20 .
__________________________
XX, Plaintiff

1.2 INSTRUCTIONS

Your response to each interrogatory should:
a. IDENTIFY each document that forms a basis for, or supports, the response given;
b. State whether the information furnished is within your personal knowledge and, if not, IDENTIFY each PERSON to whom the information is a matter of personal knowledge;
c. State if any DOCUMENT relating to anything asked about in these interrogatories has been destroyed and IDENTIFY all facts concerning the DOCUMENT and its destruction;

If any request herein to "IDENTIFY each/all/every DOCUMENT..." applies to numerous non-substantive items (eg. a litigation file containing many proofs of services and strictly procedural items) you can IDENTIFY the individual substantive items and just briefly describe the others as a group, but it must be clear you did so.

If any request herein to "IDENTIFY each/all/every DOCUMENT..." applies to a large number of strictly repetitive or redundant items you can IDENTIFY only the most complete or representative items and just briefly describe the others as a group. However, you must state that you did this and you must specifically certify that all information in the omitted group is present in no less accessible form in the DOCUMENTS you IDENTIFY.

To the extent you assert any privilege and decline to respond to any part of these interrogatories, specify the privilege and state all foundational facts justifying its assertion.

1.3 GENERAL QUESTIONS

IDENTIFY each PERSON who prepared or helped prepare your responses to these interrogatories.

IDENTIFY yourself and state:
a. Your date and place of birth;
b. Each name you used since birth and the dates used;
c. Your ADDRESSES for the last ten years and dates used.

IDENTIFY each school you have attended beginning with high school and for each give:
a. The dates attended;
b. The highest grade completed;
c. The degrees received.

IDENTIFY each employer and self-employment you have had during the last ten years and for each give:
a. The dates employed;
b. The nature of your work;
c. Your job title;
d. The reason you left.

If you are not a natural individual person state:
a. The type or form of legal entity you are;
b. All names you used for the past 10 years and dates used;
c. The date and place of your incorporation or formation;
d. The ADDRESS of your principal place of business;
e. The IDENTITY of your Board members and executive officers;

IDENTIFY any licensing or registration of you with, or by, any public entity during the past ten years.

IDENTIFY any business or professional titles, licenses or certificates you possess.

IDENTIFY any business or professional organizations you are a member of and the offices or positions held in each.

IDENTIFY any fictitious name you have registered or done business under during the last ten years.

Have you ever been convicted of, or pled guilty or no-contest to, a felony or misdemeanor? If so, for each instance IDENTIFY:
a. Its LOCATION and date;
b. The offense;
c. The court and case number.

During the last ten years has any PERSON alleged claimed or charged that YOU were in any manner involved with any wrongful, tortious or illegal act that is the same or similar to any such act, or claim for relief, which the COMPLAINT alleges you were involved with? If so, for each instance IDENTIFY:
a. The PERSON who made or filed the allegations;
b. The details of the allegations;
c. The PERSON the allegations were made to or filed with;
d. Any investigation, hearing, trial, proceeding or action related to the allegations including its outcome or result.

IDENTIFY each policy of insurance through which you were or might be insured in any manner for any claims, damages or actions arising from, or related to, the COMPLAINT and as to each state:
a. The kind and limits of each type of the policy's coverage;
b. Whether any reservation of rights or controversy or coverage dispute exists between you and the insurance company.

Specify the statute under which you are self-insured for any claims, damages or actions related to the COMPLAINT.

IDENTIFY any agreement or arrangement that may indemnify you for any costs, claims, damages or actions related to the COMPLAINT.

IDENTIFY any agreement or arrangement under which you will or may indemnify another PERSON for their costs, claims, damages or actions arising from, or related to, the COMPLAINT.

IDENTIFY each individual who witnessed any of the COMPLAINT'S alleged WRONGFUL ACTS and specify the acts they witnessed.

IDENTIFY each PERSON you claim knows of any of the COMPLAINT'S alleged WRONGFUL ACTS and specify the acts they know of.

IDENTIFY each individual YOU interviewed concerning any of the COMPLAINT'S alleged WRONGFUL ACTS and IDENTIFY the interview.

IDENTIFY each DOCUMENT created by, or that YOU obtained from, any PERSON concerning any of the COMPLAINT'S alleged WRONGFUL ACTS.

IDENTIFY each COMMUNICATION YOU participated in, or know of, concerning any of the COMPLAINT'S alleged WRONGFUL ACTS.

IDENTIFY each PERSON who you claim has knowledge of any of PLAINTIFF'S injury or damage alleged in the COMPLAINT and specify the injury or damage they have knowledge of.

IDENTIFY each DOCUMENT created by any PERSON concerning any of PLAINTIFF'S injury or damage alleged in the COMPLAINT.

IDENTIFY each COMMUNICATION YOU participated in, or know of, concerning PLAINTIFF'S injury or damage alleged in the COMPLAINT.

IDENTIFY any surveillance of PLAINTIFF by YOU and IDENTIFY any DOCUMENT arising from, or relating to, such surveillance.

IDENTIFY any PERSON who's violation of any statute, regulation or ordinance you contend was a proximate cause of any of the damage to PLAINTIFF alleged in the COMPLAINT and specify each statute, regulation or ordinance you contend was violated.

Specify each of the COMPLAINT'S material allegations that you deny, and for each IDENTIFY:
a. The facts on which you base the denial;
b. Any PERSON with knowledge of those facts;
c. Any DOCUMENT which supports your denial.

Specify each special or affirmative defense you assert regarding the COMPLAINT, and for each IDENTIFY:
a. The facts on which you base the defense;
b. Any PERSON with knowledge of those facts;
c. Any DOCUMENT which supports your defense.

IDENTIFY any PERSON, other than those named in the COMPLAINT, who you contennd contributed to the occurrence of the COMPLAINT'S alleged WRONGFUL ACTS, injuries or damages, and IDENTIFY:
a. The facts on which you base your contention;
b. Any PERSON with knowledge of those facts;
c. Any DOCUMENT which supports your contention.

If you contend that the PLAINTIFF was not injuried or damaged by the COMPLAINT'S alleged WRONGFUL ACTS, IDENTIFY:
a. The facts on which you base your contention;
b. Any PERSON with knowledge of those facts;
c. Any DOCUMENT which supports your contention.

If your response to any request in Plaintiff's First Request For Admissions, dated , 20 , is anything other than an unqualified admission, state the number of the request and IDENTIFY:
a. Each fact upon which you base your response;
b. Each PERSON having knowledge of those facts;
c. Each DOCUMENT that supports your response;

2 ADMISSIONS

XXXX )
PLAINTIFF, ) PLAINTIFF'S FIRST REQUEST
) FOR ADMISSIONS TO
v. )
)
XXXX )
DEFENDANTS. )
_________________________________)

PROPOUNDING PARTY: Plaintiff XX

RESPONDING PARTY: Defendant xx.

SET: One.
Plaintiff requests you respond to the following "Requests for Admissions" in conformity with Federal Rule of Civil Procedure 36.

DEFINITIONS AND INSTRUCTIONS

REQUESTS FOR ADMISSIONS

ADMIT pursuant to Rule 36, FRCivP that:

Dated: , 20 .
__________________________

3 PRODUCTION REQUESTS

XXXX )
PLAINTIFF, ) PLAINTIFF'S FIRST REQUEST
) FOR PRODUCTION OF DOCUMENTS
v. ) TO
)
XXXX )
DEFENDANTS. )
_________________________________)

PROPOUNDING PARTY: Plaintiff XX

RESPONDING PARTY: Defendant xx.

SET: One.

Plaintiff requests that you produce the following documents on xx, 199X at 10:00 a.m. at XXX, or such other place as may be mutually agreed upon, for inspection and copying pursuant to Rule 34, Federal Rules of Civil Procedure, and that you serve a verified written response and otherwise comply with the Federal Rules.

DEFINITIONS AND INSTRUCTIONS

DOCUMENTS REQUESTED

[LIST DOCUMENTS]

Dated: , 20XX. __________________________
XX, Plaintiff

3.2 INSTRUCTIONS

Your written response to each request should, if applicable:
a. State that a requested DOCUMENTS does not exist;
b. IDENTIFY each requested DOCUMENT withheld due to any assertion of privilege, specify the privilege, and state all foundational facts you contend justify your assertion with enough facts to uniquely identify a DOCUMENT withheld based on attorney-client or work product privilege;
c. State that a DOCUMENT is not in YOUR possession, custody or control, describe in detail YOUR efforts to locate it, state its LOCATION and IDENTIFY who has control;
d. IDENTIFY the source of each DOCUMENT you produce;
e. IDENTIFY all facts regarding any requested DOCUMENT that was destroyed and the circumstances of its destruction.

If any request herein to produce "each/all/every DOCUMENT..." applies to numerous non-substantive items (eg. a litigation file containing many proofs of services and strictly procedural items) you can produce the individual substantive items and just briefly describe the others as a group, but it must be clear you did so.

If any request herein to produce "each/all/every DOCUMENT..." applies to a large number of strictly repetitive or redundant items you can produce only the most complete or representative items and just briefly describe the others as a group. However, you must state that you did this and you must specifically certify that all information in the omitted group is present in no less accessible form in the DOCUMENTS you produce.

INTEGRATED DISCOVERY REQUESTS

XXXX )
PLAINTIFF, ) PLAINTIFF'S FIRST INTEGRATED
) DISCOVERY REQUEST TO
v. )
)
XXXX )
)
DEFENDANTS. )
_________________________________)

PROPOUNDING PARTY: Plaintiff XX

RESPONDING PARTY: Defendant xx.

SET: One.

Plaintiff XX, pursuant to FRCivP Rule 26 et seq. requests defendant XX, serve a verified response to each of the following integrated discovery requests upon plaintiff within the 30 days required by the Rules.

DEFINITIONS AND INSTRUCTIONS

In answering any interrogatory, please provide the following information: (a) IDENTIFY each document that forms a basis for, or supports, the response given; (b) State whether the information furnished is within the personal knowledge of the PERSON answering and, if not, the IDENTITY of each PERSON to whom the information is a matter of personal knowledge; (c) If any DOCUMENT relating to anything asked about in these interrogatories has been destroyed IDENTIFY all facts concerning the DOCUMENT and its destruction;

Your written response to any document production request should state the following: (a) Whether no DOCUMENTS exist; (b) If you withhold any DOCUMENT because of a claim of privilege, IDENTIFY each such DOCUMENT and the specific ground for withholding it; (c) If your response is that any requested DOCUMENTS are not in YOUR possession, custody or control, describe in detail the efforts YOU made to locate the DOCUMENTS and IDENTIFY who has control and the LOCATION of the DOCUMENTS; (d) IDENTIFY the source of each DOCUMENT you produce; and (e) If any requested DOCUMENT has been destroyed IDENTIFY all facts concerning the DOCUMENT and its destruction.

To the extent that you interpose any privilege and decline to respond to any part of any herein interrogatories or admission requests; in the answer to each such request identify the privilege and state all foundational facts you contend justify invocation of said privilege, including sufficient facts to uniquely identify any information withheld on the grounds of the asserted privilege.

INTEGRATED DISCOVERY REQUESTS

(a) ADMIT pursuant to Rule 36, FRCivP that:

1.

(b) If your response to any of the above requests for admissions is anything other than an unqualified admission, as an answer to this Interrogatory pursuant to Rule 33, FRCivP, IDENTIFY separately as to each such request: (i) Any facts you contend justify anything other than an unqualified admission; (ii) Any PERSON with knowledge of such purported facts; and (iii) Any DOCUMENTS that support your answer.

(c) If you have identified any DOCUMENTS pursuant to the above interrogatory, produce pursuant to Rule 34, FRCivP, the original of each such DOCUMENT in YOUR constructive or actual possession, custody or control, for inspection and/or copying at a mutually satisfactory place and time, and agree in writing to such production pursuant to the Rule within thirty days.

(d) If you have any DOCUMENTS to produce responsive to the call for production hereof, admit pursuant to Rule 36, FRCivP that each is genuine and authentic.

(e) As an answer to this Interrogatory pursuant to Rule 33, FRCivP, IDENTIFY any document you contend is relevant to the request for admission made in part (a) hereof and your answer to part (b)(iii) hereof, but not produced for any reason.

Dated: , 20 .
__________________________
XX, Plaintiff

-----

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