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With respect to the representative of a party other than the party's attorney, discovery shall not include disclosure of his or her mental impressions, conclusions or opinions respecting the value or merit of a claim or defense or respecting strategy or tactics.

A sample discovery deficiency letter that a party to a civil action in a Pennsylvania court of common pleas may use to inform another party or a subpoena recipient that they have failed to provide an adequate document production, deposition testimony, or set of responses to written discovery requests.

(a) Subject to the provisions of Rules 4003.2 to 4003.5 inclusive and Rule 4011, a party may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery or to the claim or defense ...

In short, the discovery process is a method by which opposing parties in a court proceeding learn more about certain witnesses and evidence that will be presented at an upcoming trial.

Before any disclosure or discovery can be sought under these rules by either party, counsel for the parties shall make a good faith effort to resolve all questions of discovery, and to provide information required or requested under these rules as to which there is no dispute.

Rule 4005 - Written Interrogatories to a Party (a) Subject to the limitations provided by Rule 4011, any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is a public or private corporation or similar entity or a partnership or association, by any ...