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A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items. (NRCP 34; JCRCP 34.)
If your case is an unlimited civil case (over $25,000) you may ask up to 35 special interrogatories, but may ask more with a declaration explaining the need for additional requests and a statement that the request is not done for an improper purpose.
Interrogatories allow the parties to ask who, what, when, where and why questions, making them a good method for obtaining new information in a case. There are two types of interrogatories: form interrogatories and special interrogatories.
You use different types of discovery requests to get different kinds of information: To ask the other side to answer a set of questions, you can use Interrogatories. To ask the other side to admit that certain facts are true or certain items are authentic, you can use Request for Admission.
These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.