I'll take a look at this tonight and get back with you.
As I understand it, discovery is not filed with the court.
So, would I only need to send the request to the attorney for the County and
not have to send it to every attorney and defendant involved in the case ? Thanks. No hurry.
I reviewed that and they look fine, just be aware that any request for production that asks for "all documents" without being very specific is probably going to draw an "overbroad, vague and ambiguous" objection.
Also, did I mention getting the discovery book at http://www.lessonsinlaw.com/the-guerrilla-guides-to-the-law/the-guerrilla-guide-to-written-discovery-civil/ ?
That has a good section on how to use interrogatories to identify documents to request in the requests for production.
You would want to send interrogatories and requests for production to every defendant. You want to send a set directed to them to be answered and then a copy of what you send to everyone else.
I am still unclear about . . . 1) Should I send copies of discovery requests to all defendants even though a request is only directed at one defendant ? 2) Can I send more than one discovery request to the same defendant ? 3) Should I provide an expected completion date or ask for an estimate on how long it will take to produce documents ?
1) Yes, anytime you send anything to a defendant, cc: the others on it.
2) You are limited by the rules of discovery in your particular court. The FRCP 33 allows you to send up to 25 interrogatories per party and usually a judge lets you divide these up into at least two sets. So, for example, you could send 15 in the first set and 10 in the second set. However, most federal courts now have their own "local rules" which can vary that number. In addition, most federal courts have a "mandatory disclosure" which each side must make to the other so there is no need to use an interrogatory asking about something that would be covered by the mandatory disclosure. Be sure you read up on the FRCP for each type of discovery and then, in addition, read your local rules and the one(s) on mandatory disclosures.
3) Teh rules state how long they have to respond. FRCP 33(b)(2) specifically states the party has 30 days after they have been served with the interrogatories. That doesn't mean served as in a process server has to give it to them, you can serve by fax or certified mail and certified mail is the best way.
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