Draft Interrogatories to the Defendant in a Personal Injury Case
Drafts numbered interrogatories to a personal injury defendant, each tied to its source and the element it serves, sized against the numerical limit only if you paste the governing rule, with limits, timing and format left for you to confirm.
The Prompt
Variables (7)
| Variable | Description | Example |
|---|---|---|
| {{requesting_party}} | Requesting Party | Plaintiff Maria Gonzalez |
| {{court}} | Court and Jurisdiction | Superior Court of Fulton County, Georgia (state court) |
| {{governing_rules}} | Governing Discovery Rules | Paste the rule text on interrogatories, including any numerical limit, response time and format requirements, and any scheduling order provision. |
| {{responding_defendant}} | Responding Defendant | Sunline Logistics LLC, a corporation |
| {{claims_and_elements}} | Claims and Elements | Negligence: duty, breach (running a red light, driver fatigue), causation, damages. Negligent hiring and supervision. |
| {{disputed_issues}} | Disputed Issues | Defendant's answer denies fault and pleads comparative negligence; disputes speed at impact. |
| {{case_facts}} | Case Facts and Evidence | E1: Police report 06/14/2026 p.2: "Unit 2 entered the intersection against the red signal." E2: Dashcam clip, timestamp 14:32:08... |
Expected Output
Two parts. Part 1, attorney-only notes: an evidence register with quotes, conflicts between sources, a request table tying each interrogatory to its source and the element or defense it serves, the count with a ranking and cut order, unsupported statements declined, declined requests and missing information. Part 2, the interrogatories as served: definitions, instructions, numbered single-topic interrogatories and signature and service lines left for you to complete. A verification list closes the output.
Usage Notes
Use once the defendant's answer is in and you know which defenses are actually raised. Paste the discovery rule text that governs in your court, including any cap and response time: the prompt will not supply them, will not assume the Federal Rules and will not size the set to a limit that only appears in someone's letter. Failure modes to watch: a question that assumes a date, sequence or fault the source does not state, a question that treats one of two conflicting records as the fact, and several topics folded into one interrogatory so that the set exceeds your limit. Check the count and the subparts against the pasted rule. Read the document part line by line before it leaves the office. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Legal Sources Referenced
- Fed. R. Civ. P. 33 (interrogatories to parties: numerical limit, time to answer and objections in federal court, unless otherwise stipulated or ordered)
Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions
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* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.