Creating a good "Discovery Plan" should be part of every case opened in your office. Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action.We recently added a new product discovery document to our planning process. We call it the Discovery Brief. Plaintiff's Notice to Produce Documents in a Product Defect Case with. Jurisdictional and Successor Liability Issues as to Certain Defendants. PI021A. These are the official forms for use in Surrogate's Court proceedings. Numerous factors could cause the actual quantities of Products purchased under this Contract to vary substantially from the estimates in the Solicitation. Notice was mailed out. Page 60. 133. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13.