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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.
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.
How To Write a Discovery Request for Production Have a Meet-and-Confer Session. The first step is to meet and confer with the other party. ... Determine the Evidence That You Need. The next step is to determine what type of evidence you need. ... Create a Request. ... Wait for a Response.
Topics Covered: hide 1.1 # Don't ask what you already know. 1.2 # Don't Talk (too much) 1.3 # Don't pop the question, yet! 1.4 # Don't jump in without an agenda: 1.5 # Don't miss the pain points : 1.6 # Don't just call: 1.7 # Don't assume :
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.