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Discovery requests and responses: keeping them organized

Interrogatories, requests for production and requests for admission each come with their own deadlines and documents. A simple tracker keeps every one accounted for.

Legal support4 min readCorvane Ashmoor & Co.

Written discovery generates a lot of moving parts: dozens of numbered requests, each with a response date, objections, documents and supplements. Missing one can cause real problems, so firms of every size rely on a tracker.

Track each set

  • The type: interrogatories, requests for production or requests for admission.
  • Who served it and on whom.
  • The date served and the response date counsel has calculated.
  • Extensions agreed in writing.

Organize the documents by request

For requests for production, keep an index that ties each Bates range to the request number it answers. When a dispute arises, counsel can show exactly what was produced for each request.

Supplements and follow-ups

Responses often need supplementing as new information arrives. Note open items and follow-up dates so nothing falls through.

The decisions stay with counsel

Deadlines, objections and what to produce are legal judgments for the supervising attorney. Support work keeps the information organized and the dates visible.

Our discovery tracker keeps every set and its date in one place.

Litigation support is performed at the direction of a licensed attorney. Counsel calculates and confirms every deadline under the applicable rules.

This article is general information, not legal, tax or regulatory advice. Rules change; confirm current requirements with the responsible agency or a licensed professional.

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