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Ask probing questions instead of yes/no questions You'll get much more information by asking open-ended questions. Instead of ?Is your team made up of SDRs and AEs??, ask: ?Can you tell me about your team's structure?? That said, sometimes customers aren't sure how to answer an open-ended question like this.
Read and answer the questions Read the question very carefully. Answer only the question that is asked, and avoid the temptation to over-explain your answer. If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question.
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.
Discovery requests typically follow a common format that you can mirror. First, list instructions detailing the request for production. Be sure to mention Rule 34 and Rule 26(b), which outline the scope of the discovery request. It's also necessary to include a section with definitions.
You can request documents that are relevant to your court case that the other party has access to. You can also request physical items to look at (?inspect?).