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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).
Read each question (interrogatory) 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.
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.
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.
Follow these steps to begin discovery in justice court: Step 1: Prepare and exchange your initial disclosures. Within thirty days after the defendant files his answer, the plaintiff and defendant must exchange: ... Step 2: File the early case conference report. ... Step 3: Ask the court to allow more discovery if you want it.