This is a sample for a request to answer interrogatories. Bold face are instructions and designate either the writer as the plaintiff or defendant. Use this template are your own risk as I will not be held responsible for its content.

Before the

[Whatever Court]

_________________________________________

) Date

John Doe, pro se )

Plaintiff or Defendant )

) Docket No.

Vs. )

)

John Doe, )

Plaintiff or Defendant )

)

_________________________________________)

Pursuant to the Judge’s Acknowledgment and Order (This is after pleadings have been accepted. You must reference the order of the court, in this instance we cite Federal Rules but State rules may be appropriate) and 29 C.F.R. § 1614.109(d) (2000), the plaintiff/defendant requests that the plaintiff/defendant answer the following Interrogatories under oath, separately and fully in writing, and in accordance with the definitions and instructions set forth below. The plaintiff/defendant is expected to provide written answers to the Pleadings within thirty (30) days of service of these Interrogatories.

1. The interrogatories are continuing in nature so as to require prompt supplementation or modification of responses to the full extent specified in Rule 26(e) of the Federal Rules of Civil Procedure. (Again whatever rules apply)

2. The interrogatories seek to inquire as to all information presently in the possession, custody, control or within the knowledge of the plaintiff/defendant including information contained in or on any "documents" (as defined below) or any other things known or available to the plaintiff/defendant, including all information in the possession of the plaintiff/defendant attorney, investigator, agent, or any other person acting by or on behalf of the plaintiff/defendant.

3. If the plaintiff/defendant lacks the information necessary to answer any of the interrogatories, the plaintiff/defendant is asked to describe the specific efforts made by it or anyone acting on the plaintiff/defendant behalf to ascertain the information and state as definitively as possible when the plaintiff/defendant anticipates obtaining the information and supplementing its response.

4. In answering the interrogatories, identify persons in the following manner:

a. Full name.

b. Occupation or business.

d. Business address and telephone number.

5. In answering the interrogatories where a writing is asked to be identified or is referred to in the answer, identify the writing(s) in the following manner:

a. Nature of the writing.

b. Physical description including the number of pages.

c. Date of the writing.

d. Identify the person to whom the writing is directed.

e. Identify the person by whom the writing is signed or subscribed.

f. Location of the original and all copies.

g. Identify the person who is the custodian of the original writing and all copies.

6. Where the interrogatories request a description of a statement or oral communication, state with respect to each such statement or oral communication:

a. The date and place thereof.

b. The manner of communication (i.e. in person or by telephone, etc.).

d. The substance of what was said by each person participating in the

communication.

e. Describe all writings which record, summarize, confirm, or in any manner refer to the communication.

7. Where a date is required or referred to, identify the exact date. If the exact date is unknown, identify the approximate date within the narrowest time frame possible.

8. If any answer to an interrogatory is made based on information and/or belief, state the basis for such information and/or belief.

9. If any document called for by a request for production is withheld under any claim of privilege, furnish a list identifying each document withheld, together with the following information: The date, sender, recipient, subject matter of the document, the basis for the claim of privilege and the number of the request for which each document is responsive.

1. The terms "you," "your," "plaintiff/defendant," or any synonym thereof is intended to and shall embrace and include, all agents, servants, representatives, private investigators and others who are in a position to obtain or may have obtained information for or on behalf of the plaintiff/defendant, and any and all persons acting or purporting to act on behalf of the plaintiff/defendant.

2. The term "document," as used herein, is used in its most comprehensive sense and means any writing of any kind, including the original, as well as any notations made of the original copy or otherwise. The term "document" also includes graphic or oral records or representations of all kinds, such as photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures, telefax, and mechanical, or electronic records or representations of all kinds, such as tapes, computer disks, cassettes and recordings.

3. The term "all documents" means every document, as defined above, known to you, and every document which can be located or discovered with reasonably diligent efforts.

4. The term "person" means any natural person, corporation, partnership, proprietorship, association, organization, or group of natural individuals.

5. The term "identify," when used in reference to an organization, means to state:

a. its full name; and

b. the address of its principal place of business.

6. The term "identify," when used in reference to a natural person means to state:

a. his or her full name;

7. As used herein, "describe in detail" with respect to a document means to state the date or approximate date of creation or execution; its title or heading, nature (e.g., letter, telegram, memorandum), substance and location with sufficient particularity to enable its custodian to identify it in response to a subpoena duces tecum or a motion to produce; the name, official business position and business address of its present custodian, its author and any other person who assisted in preparing it, the name/signature of the individual to whom it was released, the person to whom it was addressed and any other recipients. In lieu of providing the information requested above, the document may be identified by attaching a true and legible copy thereof to your answers to these interrogatories, together with a notation indicating to which interrogatory or interrogatories the writing or document is responsive.

8. "Regarding," "relating to," or "pertaining to," when used with respect to a document, agreement, subject or fact, means embodying, containing, evidencing, reflecting, reciting, recording, supporting, refuting, or referring to.

9. The term the Plaintiff/Defendant," shall mean the (whomever the opposing party is) and all named officials as designated in the original complaint. The term "(Company or whatever)" shall also refer to all representatives acting or purporting to act on behalf of the (Company or whatever) with respect to the matter inquired about in these specific interrogatories.

10. The term "incident" refers to the specific allegations contained in the pleadings.

11. Where the Plaintiff/Defendant is not able to answer a question in full, he must so state and set forth the portion of the answer to which he has knowledge.

12. The Plaintiff/Defendant is hereby instructed to supplement the answers to these interrogatories in accordance with the provisions of Federal Rule of Civil Procedure 33. (Again whatever rules apply)

13. Words in the masculine gender include the feminine and neuter.

14. The singular number includes the plural and the plural the singular.

15. As used herein, "identify" means to provide with respect to any act, occurrence, transaction, event, statement, communication or conduct (hereinafter collectively referred to as "act") all facts concerning any such act, including, but not limited to, a description of each act, the date, the location, and the names and addresses of all persons involved.

16. When an interrogatory asks for the factual "basis" for any contention, statement, claim, allegation, belief or conclusion, the response shall include, but not be limited to, the description identification and enumeration of:

17. As used herein, "incident" or "occurrence" means any event or events that are the basis of the complaint unless otherwise specified.

18. As used herein, "Plaintiff/Defendant" refers to the (whomever you suing or defending from) and/or any organizational component thereof, including the (Any subentities like a subordinate corporation).

19. As used herein, "claimed injury" and "injury, condition or harm" mean any injury, condition or harm of any kind (physical or otherwise) which you claim to have suffered as a result of any alleged discrimination or other conduct (or lack thereof) of any employee of the Plaintiff/Defendant.

1. Identify each and every individual who participated in answering these interrogatories. If more than one person answers an interrogatory or part of an interrogatory, identify which interrogatory or part such person answered.

2. Identify each and every individual with knowledge of the facts in this case.

3. Identify each and every individual who may or will be called to testify on your behalf at the trial and state the substance of the facts about which each individual is expected to testify. Please be sure to provide the current address and telephone number for each witness you list.

4. Identify each and every individual who has been retained on your behalf as an expert to render any opinion with regard to any of the facts in this matter.

Explain in detail the nature and composition of (This is where you get into the substance of your questions. You must number each question and end the questions with the following statement . Include the identity of any witnesses believed to have personal knowledge of any of these facts and identify, with particularity, any documents which support these factual assertions.

Respectfully submitted:

_______________________________

John Doe, pro se

CERTIFICATE OF SERVICE

Don’t forget your certificate of service