# First set of interrogatories — contract dispute

Drafts a numbered first set of interrogatories for a breach of contract case, built around your case theory and your jurisdiction's numeric limit. Reach for it after the answer comes in and you know which defenses you have to pin down.

## Prompt

## Context
You are a litigation drafting assistant for a civil case in [JURISDICTION]. I represent [CLIENT ROLE] in a contract dispute against [OPPOSING PARTY]. Dispute summary: [DISPUTE SUMMARY]. The issues I need discovery on: [KEY ISSUES]. The applicable rules cap interrogatories at [INTERROGATORY LIMIT], counting discrete subparts.

## Task
Draft a first set of interrogatories to [OPPOSING PARTY]. Cover: formation and negotiation of the contract, performance and breach, damages claimed or disputed, the affirmative defenses raised in the answer, persons with knowledge, and identification of key documents. Number each interrogatory. Stay under the limit, counting subparts.

## Standards
- Open with a short DEFINITIONS section. Define "identify," "document," "communication," and the contract at issue. Nothing else unless a question needs it.
- One fact subject per interrogatory. No compound questions that invite objections.
- Ask for facts, not legal conclusions. Contention interrogatories are allowed, but flag each one in a drafting comment so I can decide whether to serve it now or after document production.
- Plain declarative phrasing: "Identify each person who..." not "Please state whether or not..."
- Output: DEFINITIONS, then numbered INTERROGATORIES, then a short note telling me which questions are most likely to draw objections and why.
If you are missing a fact you need — contract date, breach theory, damages categories — ask me before drafting. Do not invent case details.

## Input checklist

- [ ] The complaint and answer, or a tight summary of each claim and defense
- [ ] The contract and key amendments, or at least the disputed terms
- [ ] Your jurisdiction's interrogatory limit and its subpart-counting rule
- [ ] The two or three issues this case will turn on
- [ ] Remove client-identifying details, or confirm your AI tool sits under your firm's confidentiality and bar guidance before pasting case material

## Verification checklist

- [ ] Count interrogatories including discrete subparts against the rule limit — AI miscounts subparts often
- [ ] Check the definitions against your jurisdiction's pattern; delete any defined term the set never uses
- [ ] Confirm each contention interrogatory is one you want answered now, not after depositions
- [ ] Strip any question that asks for a pure legal conclusion
- [ ] Verify party names, contract dates, and pleading paragraph references against the actual file
- [ ] Map the set against your case theory: every element you must prove gets at least one interrogatory
- [ ] Confirm the set complies with any local form requirements (line spacing for answers, certificate of service)

## Customization notes

Swap the coverage list in Task for tort, employment, or construction issues — the structure holds. For state court, replace the limit and the subpart-counting note with your state rule (some states count subparts loosely, some strictly). If the answer has not been filed yet, drop the affirmative-defense questions and add them in a second set.

---

From The Solo Attorney's AI Practice Library — vetslearn.com/libraries/attorney