Discovery materials are filed only in limited circumstances, including if ordered by the Court, if necessary to the presentation or defense of a motion, or if required by law or rule.
In the United States, there are five basic forms of discovery: depositions, interrogatories, requests for production of documents (or permission to inspect), physical and mental examinations, and requests for admission.
Information obtained during discovery shall not be filed with the court until such time as it is filed for good cause. The requirement of good cause is satisfied only where the filing of the information is allowed or required by another applicable rule of procedure or by court order.
The privilege log, appendix and accompanying memorandum of law must be sufficient to establish a prima facie case to support assertion of each privilege or protection. No party may submit documents for the Court's in camera review, unless the Court issues a subsequent order requesting such submissions.
Write out each fact you wish the other party to admit is true. When writing these facts, be as clear and concise as possible. Each request must be for a single fact; do not include multiple facts, compound questions, or subparts.
Standard Timeframe in NY: Under NY CPLR 3130, a party may serve written interrogatories upon another party after the commencement of an action. Typically, the recipient has 30 days from the date of service to respond.
Florida's statute of limitations for personal injury cases is generally two years from the date of the injury. However, the discovery rule allows for an exception: the statute of limitations may begin on the date you first discovered (or reasonably should have discovered) the injury.