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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.
This letter is often called a good faith letter. And it is needed under many courts' rules before you can file a motion to compel discovery if the other party ignores your requests or provides evasive responses or move for sanctions if your opponent refuses to comply with the court's discovery order.
Many types of discovery exist, including: Interrogatories. Requests for Admission. Production of Documents. Property Inspection. Physical and Mental Exams. Depositions.
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.