| name | interrogatories-to-defendant |
| title | Interrogatories to Defendant — Personal Injury |
| description | Drafts plaintiff's interrogatories to defendant in personal injury litigation with caption, definitions, instructions, and substantive questions. Triggers when user needs to draft interrogatories, written discovery requests to a defendant, or PI discovery sets. Enforces numerical limits, subpart counting, and contention interrogatory practices. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/interrogatories-to-defendant |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | personal-injury |
| language | en |
| tags | ["drafting","litigation","pleading"] |
Interrogatories to Defendant — Personal Injury
Drafts interrogatories that pin down defendant's factual contentions, identify witnesses and evidence, and build the foundation for depositions and trial.
Required Inputs
- Caption details — court, case number, party names
- Operative pleadings — complaint (claims) and answer (affirmative defenses)
- Jurisdiction — federal (FRCP 33) or state; confirm applicable rules
- Numerical limit — FRCP 33 default is 25 including discrete subparts; state rules vary
- Set designation — first, second, etc.
- Attorney info — name, bar number, firm, address, phone, email
Document Structure
1. Caption
Standard litigation caption. Title: "Plaintiff's [First/Second/etc.] Set of Interrogatories to Defendant."
2. Introduction
- Propound under governing rule (FRCP 33 or state equivalent)
- State response deadline (30 days unless local rule differs)
- Require separate, full, written answers under oath
3. Definitions
Define at minimum:
| Term | Scope |
|---|
| IDENTIFY (person) | Name, address, phone, employer, relationship to parties |
| IDENTIFY (document) | Author, date, type, custodian, location, Bates number |
| IDENTIFY (communication) | Date, participants, medium, substance |
| PERSON | Natural persons and all entities |
| DOCUMENT | All tangible and ESI formats |
| COMMUNICATION | Every form of information exchange |
| INCIDENT | Specific event(s) giving rise to the lawsuit |
| YOU/YOUR | Defendant including agents, employees, representatives |
Draft broadly to prevent evasion; keep defensible.
4. Instructions
- Duty to supplement (FRCP 26(e) or state equivalent)
- Answer each interrogatory separately and fully
- Privilege claims require a privilege log
- Duty to investigate despite lack of personal knowledge
- Answer subparts separately
- Business-records option under FRCP 33(d) with specification
5. Substantive Interrogatories
