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Write out each fact you wish the other party to admit is true. When writing these facts, be as clear and concise as possible. Each request must be for a single fact; do not include multiple facts, compound questions, or subparts.
Some examples that your lawyer may request as part of their motion for discovery are: Photos or videos of the crime scene. Witness statements. Police reports or notes.
Discovery may be carried out by directly asking a person questions (oral depositions), by sending a person written questions (interrogatories and depositions on written questions), and by requesting that the person provide documents (motions for production, subpoenas duces tecum).
Provide a brief synopsis (two or three sentences) of the crux of the motion that you are bringing before the court. 2. Give a good explanation of the facts of the case. The relevant scope of your discovery depends on these facts.