This template contains interrogatories that may be used by a plaintiff in a breach of contract case. This template includes practical guidance, drafting notes, and an optional clause. Interrogatories are a frequently used form of discovery, and consist of written questions propounded by one party to another. Interrogatories may relate to any matter that is relevant to the claims, issues, and defenses of any party in the subject case. The scope and extent of interrogatories will vary depending on, among other things, the allegations and complexity of the case. The party that receives the interrogatories must generally either answer the questions in writing and under oath or object to all or some of them, such as when the interrogatories seek information protected by a privilege. Interrogatories provide a useful tool to ascertain the basis for a party's claims, defenses, and/or other factual allegations being advanced in the case. Interrogatories are usually served at an early stage in the proceedings, as the responses contained therein can be used, among other things, in subsequent discovery (such as when taking depositions), to identify additional persons that may have knowledge pertaining to the case, and in motions (such as a summary judgment motion). The interrogatory answers are admissions of a party and are admissible at trial to the extent permitted by the rules of evidence. Many jurisdictions require that written responses to the interrogatories be provided within 30 days after being served with the interrogatories. However, the court rules can vary in different jurisdictions, so counsel should consult specific state court rules of procedure for response deadlines and filing requirements. For example, several states have form interrogatories that are required to be used for breach of contract claims. In those instances, you will utilize the required state forms and may need to seek approval to serve special interrogatories. These interrogatories are for use in a breach of contract case. The standard elements of a cause of action for breach of contract are (1) the existence of a valid and enforceable contract between the plaintiff and the defendant, (2) substantial performance of the contract by the plaintiff, (3) failure to perform the contract by the defendant, and (4) resulting damages. Some of the interrogatories will need to be modified and customized to address the particular facts and issues presented in the client's breach of contract case. For additional guidance, see Commercial Litigation Causes of Action, Interrogatories: Drafting and Serving Interrogatories (Federal), and Interrogatories: Responding to Interrogatories (Federal).