How to Respond To Various Types of Discovery Requests 

Written discovery is a standard process of civil litigation. Unless the case settles very quickly, all parties will be serving discovery requests on each other in order to exchange evidence that's available to each side. Below are our instructions to help you respond to the discovery requests that was served on you by the opposing party in your case:

• 1.Form Interrogatories  / Form Interrogatories Employment Law - these are questions that you have to answer under oath to the best of your ability. Be sure to answer carefully and factually every check marked interrogatory and every subsection of such interrogatory as fully as you can. Remember, you don't have to provide any more information than asked for in the interrogatory.  If you don't know the answer, please state so. If you don't know the exact answer, provide your best estimate, if you are able to.  You can draft your answers on a separate sheet of paper and return it to our office. We will then put it in form and forward back to you to review and sign the verification confirming that your responses are correct.  

• 2.Special Interrogatories - the instructions are similar to the above instructions for form interrogatories. Please fully and accuretely answer every interrogatory separately. 

• 3.Requests for Production of Documents -  please produce any and all documents that you have as responsive to each request for production that was served on you. You may or may not have certain documents requested. You only have to produce the documents you have in your custody / control / possession. Along with producing the documents requested, please provide on a separate sheet of paper a response to each request in one of the three following ways: (a) I am producing all the documents I was able to find after diligent search; or  (b) I was not able to locate any responsive documents after diligent search, but I do believe they exist; or (c) I am unable to produce any documents because no such documents exist or ever existed to the best of my knowledge. 

• 4.Requests for Admissions - please respond to each request with one of the following responses: (a) admit; (b) unable to admit or deny; (c)  admit in part and deny in part; (d) deny.  If you respond with "admit", no further information is necessary with regard to that request. If your response is anything other than "admit", then please explain why you don't fully admit or why you deny, and which witnesses and documents, if any, support your denial.