______Court
______County,
Tennessee /
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
/ Case Number
______vs. ______Plaintiff(s) Defendant(s)

To:______

Address:______

From: ______

Address:______

Telephone: ______Fax: ______E-Mail: ______

This is a request that you answer under oath, in accordance with Rule 33 the Tennessee Rules of Civil Procedures, the following interrogatories. It is also a request, pursuant to Rule 34 of the Tennessee Rules of Civil Procedure, that you produce and permit inspection of the documents listed below. In responding to these requests, you are to furnish the documents that are available to you and any to which you have access but which are currently in possession of someone else.

These requests are continuing. You are required to produce supplementary responses if your initial responses become inaccurate or incomplete before the trial. If any of the requested documents are privileged material and would otherwise be required to be produced, you are to identify that material and explain why it is privileged.

Your responses to the interrogatories are due within 30 days[45 days if they are served with the Complaint].

Inspection and copying of documents will commence at ______a.m./p.m. on______, 20___ at the office of ______[person and address]and will continue until completed.

Attach additional pages to make your responses complete.

CERTIFICATE OF SERVICE

I certify that I served a copy of these discovery requests upon the person named above at the address indicated above. I did so on or before the date below by personal delivery or by first class mail.

Dated: ______ ______

Party Seeking Information

INTERROGATORIES

  1. Identify all persons (regardless of whether you intend to call them as witnesses) who have personal knowledge of facts relevant to the claims involved in this case. Include their names, addresses, andtelephone numbers.

ANSWER:

  1. List the name, address, telephone number, qualifications, assumptions made, and opinions of each person whom youmay call as an expert witness for any purpose at any time in the case.

ANSWER:

  1. [Insert below all subsequent questions. Attach separate sheets if needed.]

ANSWER:

VERIFICATION OF RESPONSES

[required to be signed by the person answering the interrogatories]

I declare under penalty of perjury that the responses given above are true and complete to the best of my knowledge and belief.

Date: ______

Signature

STATE OF TENNESSEE

COUNTY OF ______

Sworn to and subscribed before me this ______day of ______, 20____.

My commission expires: ______

Notary Public

DOCUMENTS

[List each document. A response under oath is not required by the person responding.]

Please furnish the following:

  1. ______

RESPONSE:

2.______

RESPONSE:

DISCOVERY REQUESTS PAGE1