Section 9-11-34 - Production of documents and things and entry upon land for inspection and other purposes; applicability to nonparties; confidentiality. A party desiring to take the deposition of any person upon oral examination shall give reasonable notice in writing to every other party to the action.Discovery requests must be made in the form of a written motion. The request must be submitted to the opposing party or the State if in a criminal case. Name of Person Completing this Request. Address. City, State ZIP within 30 days from the date of this request. A discovery motion is a written request to receive discovery from the State in a criminal case. In Georgia, there is no automatic right to discovery. SC-2, Sheriff's Entry of Service.