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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.
A discovery is recognizing something that already exists for the first time, that nobody has found before, e.g. how Christopher Columbus discovered the Americas.
Many types of discovery exist, including: Interrogatories. Requests for Admission. Production of Documents. Property Inspection. Physical and Mental Exams. Depositions.
In a formal discovery, you formally ask for information and documents. You write a formal request for information. A server mails the request to your spouse. Your spouse has 30 days (35 days if served by mail inside California) to respond under oath.