Discovery Request Checklist

General

Case caption and number
Parties to whom discovery is addressed
Date discovery was served

Document Requests

Request for production of documents
Relevant date ranges specified
Define terms and scope
Number each request

Interrogatories

Number each interrogatory
Clear and specific questions
Instruction for response format

Requests for Admission

Number each admission request
Simple, direct statements for admission

Additional Items

Certificate of Service included
Proofread and review for completeness