Section 10(b) Interrogatories
(Defendant to Plaintiff)

Summary

This template is a model set of interrogatories that defendants may use in securities fraud lawsuits brought by private plaintiffs alleging claim(s) under Section 10(b) of the Securities Exchange Act of 1934. This template assumes that the interrogatories are being served on behalf of at least one business entity defendant. This template includes practical guidance, drafting notes, and optional clauses. The lead plaintiff will possess, and is obligated to produce, material that is relevant to class-related issues and defenses as well as the class representative and class counsel relationship (e.g., class representative adequacy and typicality, potential conflicts of interest), that are the subject of proper discovery requests. Damages and expert-related discovery, as well as discovery into the legal and factual bases for Plaintiffs alleged causes of action, are also common. Therefore, many of the interrogatories in this model focus on those topics. Unless otherwise stipulated or ...