PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT

Louisiana State Court

[// GUIDANCE: This template complies with the Louisiana Code of Civil Procedure (La. C.C.P. arts. 1421–1474, specifically arts. 1457–1459) and the 35-interrogatory limit. Adjust numbering, timing, and instructions as the case requires.]

I. CASE CAPTION

text
[COURT NAME]
[PARISH], LOUISIANA
DIVISION “[ ]”
DOCKET NO. [_____]

[PLAINTIFF NAME(S)], )
Plaintiff(s), )
)
v. ) PLAINTIFF’S FIRST SET OF
) INTERROGATORIES TO
[DEFENDANT NAME(S)], ) DEFENDANT [DEFENDANT NAME]
Defendant(s). )

II. PRELIMINARY STATEMENT

Pursuant to Louisiana Code of Civil Procedure arts. 1457–1459 and all other applicable law, Plaintiff propounds the following Interrogatories to Defendant [DEFENDANT NAME] to be answered separately and fully in writing and under oath within the time provided by law (15 days after service, except that a defendant served with these Interrogatories together with the petition may respond within 30 days after service of the petition). These Interrogatories are continuing in nature; Defendant must seasonably supplement answers in accordance with La. C.C.P. art. 1428.

III. DEFINITIONS

For purposes of these Interrogatories, the following defined terms apply:

1. “You,” “Your,” or “Defendant” means [DEFENDANT NAME], any parent, subsidiary, affiliate, predecessor, successor, officer, director, manager, member, employee, agent, or attorney, and all other persons or entities acting or purporting to act on Defendant’s behalf.

2. “Document” has the broadest meaning allowed by La. C.C.P. art. 1461 and includes all forms of recorded information, electronically stored information (“ESI”), tangible things, and all drafts and non-identical copies.

3. “Identify” or “Identification” when referring to:
   a. a natural person—state the full name, present or last-known address and telephone number, and the person’s present or last-known employer and title;
   b. an entity—state the full legal name, address of principal place of business, state of incorporation/organization, and the name and title of the entity’s representative most knowledgeable of the subject matter;
   c. a document—state the title, date, author(s), recipient(s), general subject matter, type of document (e.g., email, contract), and present custodian.

4. “Incident” means the event alleged in Plaintiff’s Petition that occurred on or about [DATE] at [LOCATION].

[// GUIDANCE: Add, modify, or delete definitions as appropriate.]

IV. GENERAL INSTRUCTIONS

A. Answer each Interrogatory separately, fully, and under oath.
B. If You object, state with specificity the grounds and answer the remainder of the Interrogatory to the extent it is not objectionable.
C. If any information is withheld under a claim of privilege, work-product immunity, or other protection, provide a privilege log that: (i) identifies the document or information withheld; (ii) states the privilege asserted; and (iii) provides sufficient detail to permit evaluation of the claim, consistent with La. C.C.P. art. 1424.
D. The singular includes the plural and vice versa; masculine, feminine, and neuter pronouns include all genders.
E. These Interrogatories are subject to the 35-question limit (inclusive of discrete subparts) set out in La. C.C.P. art. 1457, unless the Court orders otherwise.

V. INTERROGATORIES

[// GUIDANCE: Insert or delete to stay within the 35-interrogatory cap. Numbering will auto-adjust when edited in word-processing software.]

1. Identify every person who prepared, reviewed, or supplied information used in answering these Interrogatories, and for each such person state the specific Interrogatory(ies) for which the person supplied information.

2. State Your full legal name, all trade names, assumed names, or DBAs used in the last ten (10) years, and the address of Your principal place of business.

3. Describe in detail Your involvement in the Incident, including Your conduct immediately before, during, and after the Incident.

4. Identify all witnesses to the Incident and summarize the substance of each witness’s expected testimony.

5. Identify all documents and ESI that relate to the Incident, including photographs, videos, emails, text messages, maintenance logs, inspection reports, and internal correspondence.

6. State the factual basis for each affirmative defense pleaded in Your Answer and identify all documents or evidence supporting each.

7. If You contend that Plaintiff was comparatively at fault, state each act or omission You allege constituted fault and identify all evidence supporting that contention.

8. Identify all insurance policies (primary, excess, or umbrella) that may provide coverage for the claims asserted, including the name of the insurer, policy number, limits, and applicable endorsements.

9. State the name, address, and specialty of each expert You have retained or anticipate retaining, and for each provide:
   a. the subject matter on which the expert is expected to testify;
   b. the facts, data, or opinions to which the expert is expected to testify; and
   c. a summary of the grounds for each opinion.

10. Describe all repairs, alterations, or modifications made to the property or equipment involved in the Incident after the Incident, identifying the date, nature of the work, cost, and the persons who performed the work.

11. State all damages, costs, or expenses You claim or expect to incur as a result of the Incident, specifying each category and the amount.

12. Identify any investigation conducted by or on Your behalf concerning the Incident and state the name of the person directing the investigation, the dates it occurred, and whether any written or recorded statements were obtained.

13. Describe Your document retention/destruction policies in effect at the time of the Incident and any litigation hold implemented thereafter.

14. State whether any request for admission has been denied and, if so, state fully the factual basis for each denial.

15. Describe any disciplinary action, criminal citation, or governmental investigation that arose out of the Incident.

16. Identify all contracts, purchase orders, leases, or agreements that relate to the subject matter of this litigation.

17. If You contend that a non-party is wholly or partially responsible for Plaintiff’s alleged damages, identify the non-party, state the basis of responsibility, and identify supporting evidence.

18. State whether You have filed or will file any claims for indemnity or contribution arising out of the Incident, and identify each such claim.

19. Identify all social media accounts (e.g., Facebook, Instagram, Twitter) maintained by You that reference or depict the Incident.

20. Describe each communication between You and Plaintiff (or Plaintiff’s representatives) regarding the Incident, including the date, participants, and substance of each communication.

[// GUIDANCE: Draft additional Interrogatories as needed, ensuring the total (with subparts) does not exceed 35 absent leave of court.]

VI. VERIFICATION

text
STATE OF LOUISIANA )
PARISH OF [_] )

BEFORE ME, the undersigned Notary Public, personally came and appeared:

[DEFENDANT REPRESENTATIVE NAME],

who, after being duly sworn, stated that he/she is authorized to make this Verification on behalf of Defendant, that he/she has read the foregoing Answers to Interrogatories, and that the matters and things stated therein are true and correct to the best of his/her knowledge, information, and belief.

[DEFENDANT REPRESENTATIVE NAME]
Title: [_________]

SWORN TO AND SUBSCRIBED before me
this ___ day of __, 20.

NOTARY PUBLIC
My Commission Expires: _______
[// GUIDANCE: Verification must be signed by an individual with personal knowledge or corporate representative under oath, as required by La. C.C.P. art. 1458.]

VII. CERTIFICATE OF SERVICE

text
I hereby certify that a copy of the foregoing Plaintiff’s First Set of Interrogatories to Defendant [DEFENDANT NAME] was served on all counsel of record on this ___ day of __, 20, via [U.S. mail / hand delivery / electronic service] in accordance with La. C.C.P. art. 1313 and any applicable court rules.

[ATTORNEY NAME] (#__)
[Firm Name]
[Address]
[Telephone]
[Email]
Counsel for Plaintiff

[// GUIDANCE:
1. Review Local Rules for the parish and division to confirm any additional certificate or filing requirements.
2. If electronic filing/service is used, modify the Certificate of Service accordingly.
3. Maintain strict compliance with the 35-interrogatory limit, response deadlines, and privilege-log rules to avoid objections or motions to compel.]

END OF DOCUMENT