Sample interrogatories that a defendant may use to seek information from a plaintiff in a common law action for defamation. This Standard Clause contains integrated drafting notes with important explanations and tips. Counsel should integrate the interrogatories in this Standard Clause as applicable into a larger, formal set of interrogatories specifically drafted for use in the relevant jurisdiction. Counsel should also check local rules to verify the appropriate use and permissible types of interrogatories in a defamation case in the relevant jurisdiction.