9. Trial Prep

At some point in your case, you may receive notice that we received discovery requests from the opposing party. Discovery is the process whereby each party in a lawsuit collects information and documentation relevant to the case from the opposing party.

If we are served with discovery we need to move quickly because we have to respond within thirty (30) days. So we need your responses earlier than that so that we will have time to format, edit, and gather any additional information and documentation needed from you.

  1. Interrogatories - These are questions which require your response under oath. Please answer each and every question as fully as possible, including all sub-parts. Please type your responses directly into the Word document. Do not worry about the legalese and such, as we will review and revise your responses (if necessary) before they go to the other side.

  2. Request for Production of Documents – These are documents you are required to produce to the other side. Please list the responsive documents you are providing as your response to each request. If a paragraph does not apply to you and/or your family, please use “not applicable” as your answer.

    What are acceptable responses to items that are being requested?

  • If the document is in your possession, identify the document(s) in your possession (i.e. Year 2013, 2014 S. and Georgia tax returns) and indicate that “the following documents are attached.”

  • If the document is not in your possession, then respond by indicating that “I have no such documents in my possession.”

  • If the document is not in your possession but you can get it later, then respond by indicating that “I have no such documents in my possession. I have requested the documents and will provide them when I receive them.”

  • If the documents don’t exist – e. the opposing counsel or opposing party is asking for stocks and bonds and you don’t have any – then state “I do not have any accounts that would result in the documents requested.”

  • If the document is in opposing party's possession, then respond by indicating that “the requested documents are in opposing party's possession.”