Interrogatory builder

Starting bank only. These are general-purpose questions to adapt, not case-specific drafting. The 25-question federal default may not match your court's local rules, which sometimes count subparts separately or set a different limit entirely. See our full disclaimer.

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What's the difference between identification and contention interrogatories?

Identification interrogatories ask for basic facts, such as the identity of witnesses, documents, or communications, and are used to plan further discovery like depositions and document requests. Contention interrogatories ask the opposing party to state the factual basis for a specific claim or defense, forcing them to commit to a position under oath early in the case. Contention interrogatories are often deferred by courts until later in discovery, since a party may not yet know their full factual basis early in a case, so check your jurisdiction's timing rules before serving them at the outset.

Under FRCP 33, a single numbered interrogatory asking about multiple distinct subparts, such as the formation, performance, and termination of a contract all in one question, is often counted as multiple interrogatories toward the 25-question limit, not just one. Drafters who front-load compound questions risk exhausting their limit before reaching their most important topics. Once your set is built, our discovery request generator can help draft matching requests for production, and our case deadline calendar helps track the 30-day response window.

Should contention interrogatories be served early or late in discovery?

Many practitioners recommend serving contention interrogatories relatively late in discovery, after documents have been exchanged and depositions have started, so the responding party can't simply defer answering until more information is available. Some jurisdictions specifically permit courts to defer contention interrogatory responses until closer to the close of discovery, so check local rules and any case management order before deciding on timing.

What makes a damages interrogatory actually useful?

An effective damages interrogatory asks the responding party to itemize every category of loss claimed and state the dollar amount for each category, then follows up by asking them to identify every document supporting each calculation. This locks the opposing party into specific figures early and often reveals gaps in their damages theory well before trial.

Are expert interrogatories different from deposing the expert directly?

Yes, expert interrogatories under FRCP 26(b)(4) can be used to discover the identity, opinions, and general basis for an expert's anticipated testimony, often before a full expert deposition is taken. They're generally less detailed than deposition testimony but can help narrow the scope of what actually needs to be covered in the deposition itself.

Frequently asked questions about interrogatories

It depends on how the subparts are counted, which is a common source of dispute. A single interrogatory asking for a witness's name, address, and phone number is typically treated as one question, while a single numbered question covering 3 unrelated topics is often treated as 3 separate interrogatories toward the 25-question limit. Courts generally look at whether each subpart could logically stand alone as its own question.

A responding party served with more than the allotted number can generally answer the first 25 and object to the rest as exceeding the limit, though practice varies. This is exactly why sequencing matters, since front-loading less important questions can mean the most valuable ones go unanswered if the set exceeds the cap.

Yes, under FRCP 33(a)(1), a court may grant leave to serve additional interrogatories beyond the 25-question default if the requesting party shows good cause, typically based on the complexity of the case or the number of parties and issues involved. This isn't automatic and requires a specific motion explaining why the standard limit is insufficient.

Yes, under FRCP 26(b)(1), discovery generally must be relevant to a party's claim or defense and proportional to the needs of the case. Interrogatories seeking information with no clear connection to the issues in the case are vulnerable to a relevance objection and may be limited or disallowed by the court.

Yes, ambiguous language is one of the most common reasons interrogatories draw evasive or incomplete answers, and overly broad language is one of the most common reasons they draw a formal objection. Clearly defined terms, such as precisely what "identify" or "document" means in the definitions section of the discovery request, produce meaningfully more useful answers.