Fill in the top of the Discovery form the same way you filled in the top of your Answer form in Booklet 3. Read over your Answer.Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action. How to send Discovery requests to the Plaintiff ; 1. Fill out the form(s). Discovery motions are highly technical and must be done correctly or the motion will be denied. The format must conform with Mass.R.Dom.Rel. In certain situations, a lawsuit must be filed in a Massachusetts personal injury case. Massachusetts Rules of Civil Procedure - Requests for Production Middlesex - Massachusetts Superior Court - Local and Federal Court Rules Made Easy. A second major innovation - mandating discovery without the need for motions or argument - is designed to manage court events more efficiently.