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Organize documents. Organize according to the demand number. Don't duplicate documents. If you're providing three years of bank statements in response to one demand, and the same documents contain information responsive to another demand, state so. Comply with the due date. Communicate. Do a complete job.
That disclosure is accomplished through a methodical process called "discovery." Discovery takes three basic forms: written discovery, document production and depositions.
Step 1: Prepare and exchange your initial disclosures. Within thirty days after the defendant files his answer, the plaintiff and defendant must exchange: Step 2: File the early case conference report. Step 3: Ask the court to allow more discovery if you want it.
Have a strategy. Adjust the scope of your requests to the questions at issue. Send clear requests. Always consider how your client would be prepared to respond to similar requests. Make your objections clear and specific.