LAW OFFICE OF ARKADY ITKIN
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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. 

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Law Office of Arkady Itkin

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Law Office of Arkady Itkin - San Francisco & Sacramento Injury and Employment Lawyer
We represent employees and employers in employment and wrongful termination cases, as well as victims of serious injuries in San Francisco, Oakland, Sacramento, San Jose, Palo Alto, San Mateo and throughout Northern California. We all represent businesses and start-ups in a wide range of business and employment issues and disputes. 


57 Post Street, Suite 812, San Francisco, CA 94104; Tel. (415) 295-4730; Fax. (415) 508-3474; [email protected]
  • Home
  • Employment Law
    • Wrongful Termination >
      • At-Will Employment
      • Termination After Unfair Warnings and Write-Ups
      • Union Grievance, Workers Comp and Wrongful Termination
      • Labor Code 970 Claims
      • Promissory Estoppel and Employment Contracts
      • Implied Contract Claims
    • Discrimination >
      • Proving Discrimination
      • Age Discrimination
      • Disability Discrimination >
        • Protected Disabilities
        • Medical Leave / Disability Accommodations
        • Job Reassignment As A Disability Accommodation
        • SSI Disability Benefits and Your Court Case
        • Sample Request for Reasonable Accommodation
      • Pregnancy Discrimination
      • Race Discrimination
      • Sample Discrimination Complaint
      • DFEH and EEOC Investigations
    • Retaliation >
      • How to Prove Retaliation
      • Dealing with Retaliation While Still Employed
      • Retaliation for Complaining
      • Whistleblower Retaliation
    • Harassment
    • Defamation at Workplace
    • Prof. License Defense
    • Leaves of Absence >
      • Medical Leave as Reasonable Accommodation
      • FMLA Entitlement and Reinstatement to Work
      • CFRA Leave
      • Employers' FMLA Notice Obligations
      • Paternity Leave (FMLA)
      • Sample FMLA Leave Request
    • Wages / Overtime Claims >
      • Wage Claims
      • Employee or Contractor
      • Exempt / Non-Exempt >
        • Admistrative Exemption
        • IT Support Specialists Compensation
        • Computer Professional Exemption from Overtime
        • Recruiters / Account Executives Exemption
        • Complaining About Being Misclassified
      • Vacation Pay / PTO
      • On-Call Time Compensation
      • Deductions fr. Commissions
    • Unempl. Benefits Appeals >
      • Tips for EDD Phone Interview
      • Unemployment Benefits Appeal Hearing Representation
      • CUIAB Hearing Tips
    • Employment Law Blog
    • For Employers
  • Personal Injury
    • Five Tips For Injury Cases
    • Slip-and-Fall Injuries
    • Assault and Battery
    • Recorded Statements
    • Repairing Your Vehicle
    • Unpaid Medical Bills
    • Injury Law Blog
    • Medical Malpractice
    • Police Excessive Force
  • Practice Areas
  • About
  • Results
  • Submit Case
  • Contact
  • Resources
    • Consultations
    • Workplace Rights Checklist
    • Deposition Tips
    • Mediation Tips
    • Effective Mediator
    • Suing Current Employer
    • Severance Agreements
    • Workplace Investigation
    • Arbitration
    • Statutes of Limitations
    • Healthy Litigation Mindset
    • Trial Tips
    • Working Remotely
    • How To Find The Right Lawyer For Your Case