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For document discovery to be effective, it needs to be well planned.Have a strategy.Adjust the scope of your requests to the questions at issue.Send clear requests.Always consider how your client would be prepared to respond to similar requests.Make your objections clear and specific.11-Jun-2019
No rule requires notarization of interrogatory answers. Rather, MCR 2.309(B)(3) only requires that the person making the answers sign the document.
MCR 2.309(A)(2) Availability; Procedure for Service; Limits Each separately represented party may serve no more than 20 interrogatories on each party. A discrete subpart of an interrogatory counts as a separate interrogatory.
Michigan Courts To Limit Interrogatories and Require Initial Disclosures, Starting in 2020. Lawyers, take note: On June 19, 2019, the Michigan Supreme Court amended the court rules covering discovery in civil cases. The new rules take effect on January 1st, 2020.