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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.
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 use discovery to find out things like: What the other side plans to say about an issue in your case. What facts or witnesses support their side. What facts or witnesses support your side.
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).
You must respond to the request and swear under oath that your response is true. Then you'll deliver your response to the other side's attorney (or to the other side, if they don't have an attorney).