Need help drafting interrogatories? Get instant access to sample interrogatories tailored for key civil litigation case types. Build stronger cases with the right questions—every time.
Interrogatories are more than just a discovery formality—they’re strategic instruments that can shape the entire course of litigation. Whether you’re uncovering timelines, pressuring the opposition to commit to a version of events, or gathering admissions, a well-crafted interrogatory can provide clarity, evidence, and leverage.
Yet many attorneys, especially early in their practice, struggle with how to draft interrogatories that are effective, admissible, and compliant with court rules.
In this guide, Legal Husk presents detailed sample interrogatories for six common civil case types:
Personal Injury
Breach of Contract
Employment Disputes
Real Estate Litigation
Consumer Protection
Business Torts
Each section includes interrogatory examples, use-case explanations, and drafting tips—designed to help you file smarter discovery requests and stay one step ahead.
Objective: Establish liability, causation, and damages while uncovering facts about the incident and medical treatment.
INTERROGATORY NO. 1: Identify the date, time, and location of the collision that forms the basis of this lawsuit.
INTERROGATORY NO. 2: State whether you were using a mobile phone or other handheld device at any time during the operation of your vehicle on the date of the collision.
INTERROGATORY NO. 3: Identify all persons who witnessed the incident or were present at the scene within 30 minutes of the occurrence.
INTERROGATORY NO. 4: Describe all traffic citations you received as a result of the collision.
INTERROGATORY NO. 5: State whether you have ever been involved in any other motor vehicle accidents in the past 10 years.
In PI cases, interrogatories should build a foundation of facts, highlight potential negligence, and identify witnesses or records for follow-up.
Objective: Confirm formation of the contract, identify relevant parties, and pin down the terms allegedly violated.
INTERROGATORY NO. 1: Identify all persons involved in the negotiation, execution, or approval of the contract dated March 12, 2022.
INTERROGATORY NO. 2: State the date and method of delivery of all products or services provided under the contract.
INTERROGATORY NO. 3: Describe the specific provisions of the contract that you believe the Plaintiff breached.
INTERROGATORY NO. 4: Identify all communications, including emails or texts, between the parties related to performance or nonperformance under the contract.
INTERROGATORY NO. 5: State whether any oral modifications to the written contract were made, including the terms and dates of such modifications.
Make interrogatories chronological and fact-centered—don’t leap into legal conclusions or arguments. You're building a factual record.
Objective: Clarify employment timelines, job duties, disciplinary history, and the employer’s basis for adverse actions.
INTERROGATORY NO. 1: Identify the date you first began employment with the Defendant, your job title, and the departments in which you worked.
INTERROGATORY NO. 2: Describe any complaints you made about unlawful or unethical conduct during your employment, including dates and persons notified.
INTERROGATORY NO. 3: State the reasons given to you, if any, for your termination and identify who communicated those reasons.
INTERROGATORY NO. 4: Identify any internal investigations conducted in relation to your complaints, including the names of individuals interviewed.
INTERROGATORY NO. 5: State whether you were provided with any warnings, write-ups, or disciplinary actions prior to termination.
Ask for both objective facts (employment timeline, documents) and subjective responses (alleged reasons for firing). These will form the basis for inconsistencies and depositions.
Objective: Determine property interests, contract formation (if any), inspection/disclosure practices, and notice.
INTERROGATORY NO. 1: Identify all individuals who inspected the property prior to the closing date of July 15, 2023.
INTERROGATORY NO. 2: State whether you were aware of any defects, mold, or water intrusion in the basement prior to the sale of the property.
INTERROGATORY NO. 3: Describe all representations made to the buyer regarding the condition of the plumbing and electrical systems.
INTERROGATORY NO. 4: State whether any repairs were conducted on the roof within five years prior to the sale, including the name of any contractors used.
INTERROGATORY NO. 5: Identify any property disclosure forms completed by you in connection with the transaction.
Real estate interrogatories must pin down timelines, contractual obligations, and disclosure content—especially in fraud or non-disclosure claims.
Objective: Clarify representations made to the consumer, terms of the transaction, and policies in place.
INTERROGATORY NO. 1: Identify all advertisements, warranties, or representations made about the product prior to Plaintiff’s purchase.
INTERROGATORY NO. 2: State whether any complaints were previously made regarding the model in question, including dates and outcomes.
INTERROGATORY NO. 3: Describe your company’s policy for handling defective product complaints during the relevant period.
INTERROGATORY NO. 4: Identify all persons involved in the Plaintiff’s return or refund request, including titles and dates of interaction.
INTERROGATORY NO. 5: State whether Plaintiff was offered any repair, replacement, or refund, and the terms of such offer.
Focus on the consumer experience, internal company processes, and prior incidents that show pattern or policy issues.
Objective: Establish intent, communications, damage causation, and financial harm in disputes like tortious interference, defamation, or trade secret misappropriation.
INTERROGATORY NO. 1: Identify all individuals with whom you communicated regarding the Plaintiff’s contractual relationship with XYZ Corp.
INTERROGATORY NO. 2: State whether you were aware of the existence of a contract between Plaintiff and XYZ Corp at the time of any such communication.
INTERROGATORY NO. 3: Describe all actions taken by you or your agents to induce XYZ Corp to breach or terminate its agreement with Plaintiff.
INTERROGATORY NO. 4: Identify any financial benefit your company received as a result of XYZ Corp’s termination of its relationship with Plaintiff.
INTERROGATORY NO. 5: State whether you received any legal advice or correspondence regarding your interactions with XYZ Corp.
Interrogatories in business tort cases should explore intent, knowledge, and damages—often requiring carefully phrased definitions and date-specific prompts.
Be specific: Generic questions yield generic answers. Tailor your language to the facts and legal claims in play.
Define key terms: If your interrogatory refers to “the Incident,” “the Product,” or “the Agreement,” define those terms in advance.
Keep it neutral: Avoid argumentative framing—your goal is facts, not admissions of liability.
Number consistently: Use bold headers for easy reference, especially if you plan to reference responses later in motions or depositions.
Review rules on limits: Most courts limit interrogatories (e.g., 25 per party in federal court), so draft efficiently.
Legal Husk recommends building an interrogatory bank categorized by claim type and jurisdiction. This saves time, improves quality control, and reduces risk of inconsistent language.
Would you like us to help you develop one for your firm? Ask about our Litigation Toolkit subscription.
Too often, lawyers treat interrogatories as obligatory filler. But done right, they’re a blueprint for your case theory, a shortcut to admissions, and a foundation for depositions and motions. Every interrogatory should serve a purpose—whether it's closing a factual gap, defining a position, or backing the other party into a corner.
Want to draft better, faster, and more strategic interrogatories? Use these templates, adapt them to your jurisdiction, and always draft with your endgame in mind.
In most jurisdictions (like under the Federal Rules), you’ll need court approval to exceed the default limit of 25. Count subparts, too.
If you receive objections, evaluate whether they are valid (e.g., vague, overbroad, privileged). If not, file a motion to compel.
Use templates as a base—but customize each question based on the facts, claims, and defenses of your case.
Yes. They are signed under oath and may be used as admissions of a party opponent.
Early in discovery. Interrogatory responses can shape document requests, depositions, and motion strategies.
Ready to move from boilerplate to battle-tested discovery? Whether you need templates, drafting services, or strategy consultation, Legal Husk is here to help.
📩 Need sample interrogatories tailored to your jurisdiction or case type?
👉 Visit: https://legalhusk.com
🔗 Learn more about our litigation services: https://legalhusk.com/services/civil-litigation
📞 Schedule a discovery consult and build a litigation strategy
that gets real answers.
File wisely. Litigate efficiently. Trust Legal Husk.
📩 Ready for a court-ready discovery at a predictable price? ContactLegal Husk for expert support.
Whether you are dealing with a complex family matter, facing criminal charges, or navigating the intricacies of business law, our mission is to provide you with comprehensive, compassionate, and expert legal guidance.
