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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.
After you complete your response to any request for written discovery, you must provide your response to the other side by serving the other side. You can serve the other side by mail. This means another adult, not you, mails your response to the other side.
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 :
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.