# Interrogatories — Debt-Buyer Case

Interrogatories are written questions the party must answer under
oath. Limit in superior court: **40 interrogatories including
subparts** (CR 33(b)).

Interrogatories are slower and less flexible than RFPs — but they
lock in answers under oath, which can be used at summary judgment
or trial.

## Format

```
[COURT HEADER AND CAPTION]

    [DEFENDANT'S] FIRST INTERROGATORIES TO [PLAINTIFF]

TO:    [Plaintiff]
AND TO: [Counsel of record]

Pursuant to CR 33 / CRLJ 33, [Defendant] requests that [Plaintiff]
answer the following interrogatories fully, in writing, under oath,
and serve the answers on [Defendant] within 30 days of service.

                    DEFINITIONS

[Same definitions as in RFPs — reuse them so plaintiff cannot argue
different meanings]

                 INTERROGATORIES

INTERROGATORY NO. 1:  Identify each entity that has ever owned the
Account from origination to the present. For each, state:

    (a) The name and address of the owner;
    (b) The date ownership was acquired;
    (c) The date ownership was transferred to the next owner (if
        any);
    (d) The document evidencing the acquisition or transfer;
    (e) The consideration paid.

INTERROGATORY NO. 2:  Identify the person(s) most knowledgeable
about the records of the Account, including:

    (a) The name, job title, and employer of the person;
    (b) The period during which the person maintained responsibility
        for the records;
    (c) A description of the records under the person's control.

INTERROGATORY NO. 3:  Identify each person You intend to call as a
witness at any hearing or trial, and for each state the substance
of the expected testimony and the basis of the witness's knowledge.

INTERROGATORY NO. 4:  State the date of the last payment made by
Defendant on the Account, the amount, and the manner of payment.

INTERROGATORY NO. 5:  State the date on which the Account was
charged off by Original Creditor, and identify the document showing
the charge-off.

INTERROGATORY NO. 6:  State in detail the calculation of the amount
claimed in the Complaint, including:

    (a) Principal balance at Charge-Off;
    (b) Interest from Charge-Off to the date of the Complaint, with
        the rate used and the authority for that rate;
    (c) Fees charged, with the basis and authority for each;
    (d) Credits or adjustments;
    (e) Any other component of the total claimed.

INTERROGATORY NO. 7:  State the legal basis on which You claim
ownership of the Account and the right to sue for the balance
claimed.

INTERROGATORY NO. 8:  Identify each collection letter, notice, or
other written communication sent by You or Your agents to Defendant
concerning the Account.

INTERROGATORY NO. 9:  State whether You have a license to conduct a
collection-agency business in Washington under RCW 19.16.110, and
if so, identify the license number, issuing agency, and expiration
date.

INTERROGATORY NO. 10:  State whether and how You have reported the
Account to any credit reporting agency. For each reporting, state:

    (a) The date of the report;
    (b) The credit reporting agency to which the report was made;
    (c) The content of the report (including any notation that the
        Account was disputed);
    (d) Whether any correction or update was submitted.

INTERROGATORY NO. 11:  Identify each contention of fact on which You
rely to establish Defendant's liability, and identify the documents
supporting each contention.

INTERROGATORY NO. 12:  Identify each employee, contractor, or agent
of Yours or of any prior owner of the Account with personal knowledge
of the Account's history, origin, or balance calculation.

INTERROGATORY NO. 13:  State the factual and legal basis for any
affirmative claim or counter-response to Defendant's defenses in the
Answer.

INTERROGATORY NO. 14:  Describe in detail the process by which You
acquired the records of the Account, including the format,
completeness, and any limitations on the records received from prior
owners.

INTERROGATORY NO. 15:  State whether Original Creditor has
represented or warranted the accuracy of the records of the Account
to You or any intermediate purchaser, and if so, identify the
document containing the representation or warranty.

DATED this ___ day of __________, 20__.

____________________________________
[Defendant Name], pro se
[Address]
[Email]
```

## Verification

Interrogatory responses must be verified under oath by the party (or
by an officer or agent authorized to respond):

```
                VERIFICATION

I, [Name], declare under penalty of perjury under the laws of the
State of Washington that I have read the foregoing responses to
Interrogatories and that the responses are true and correct to the
best of my knowledge.

Executed at [City], [State], this ___ day of __________, 20__.

____________________________________
[Name, title]
```

Watch for: plaintiff signing the verification itself (not an attorney).
An attorney signature is insufficient — the CR 33 verification must
come from the party.

## Numbering and subparts

Each request, **including subparts**, counts toward the 40-per-party
limit. Interrogatory 1 above counts as **5** (one base + five
subparts). Plan accordingly.

## Common plaintiff objections

- "Vague" → your definitions should be tight enough to defeat this
- "Overly broad" → tighten the time frame; cite proportionality
- "Calls for a legal conclusion" → interrogatories asking for
  contentions are allowed under CR 33(b)
- "Privileged" → demand a privilege log under CR 26(b)(5)
- "Not reasonably calculated to lead to admissible evidence" —
  **outdated phrasing**. The 2017 rule change replaced this with
  proportionality; cite CR 26(b)(1) directly

## Why interrogatories complement RFPs

- IROGs force **narrative under oath**; RFPs produce documents
- IROGs are harder to dodge with "not in possession" (an IROG asks
  what plaintiff knows, not what plaintiff holds)
- IROG answers can **lock in witness identifications** — plaintiff
  cannot later call an undisclosed witness
- IROG answers **pin the calculation** — every dollar claimed must
  be accounted for