Discovery deadlines are easy to calendar and easy to miss. This checklist follows a set of interrogatories, requests for production and requests for admission from service to the meet-and-confer letter.
Before service
- Confirm the case is past the initial disclosure stage and no stipulation or scheduling order changes the default timing.
- Count the interrogatories, including discrete subparts, against the numerical limit for your court.
- Match each request to an allegation or defense so relevance objections are easy to answer.
After service
Calendar the response deadline from the method of service, then calendar a reminder a week before it. When responses arrive, log each objection, note which responses are evasive, and draft the deficiency letter while the issues are fresh.
Meet and confer
Most courts require a good-faith conference before a motion to compel. Put the conference in writing, propose dates, and keep the letter focused on the specific requests still in dispute.
Our Discovery Support service prepares propounding sets, responses and privilege logs to your templates. Send the deadline and we will quote a delivery date that leaves you time to review.