Bifurcated discovery separates discovery on liability from discovery on damages or on another distinct issue.

A boilerplate objection is a generic recitation of grounds without explanation of how they apply to the specific request.

Claims file discovery is the effort to obtain an insurer's investigation and handling records, contested on work product and relevance grounds.

A contention interrogatory asks a party to state the factual basis for a claim, defense, or specific allegation.

A custodian certification is a sworn statement authenticating records as business records, avoiding live foundation testimony.

A deemed admission results when a party fails to respond timely to a request for admission, establishing the matter conclusively.

Destructive testing examines evidence in a way that alters or consumes it, requiring agreement or court order.

Discovery is the pretrial process by which parties obtain relevant, non-privileged information from each other and from non-parties under court rules.

A discovery dispute is a disagreement over the scope, adequacy, or timing of discovery, resolved through conferral or motion.

A discovery plan is the parties' proposed framework for discovery, submitted to the court after their planning conference.

The discovery response deadline is the period within which a party must answer or object to written discovery.

Discovery responses are the formal answers and objections a party serves in reply to written discovery requests.

A discovery stay suspends discovery pending resolution of a dispositive motion or another threshold matter.

The duty to supplement requires parties to correct or complete discovery responses and disclosures that become incomplete or incorrect.

Expedited discovery is discovery conducted before the normal timeline, typically in support of preliminary injunctive relief.

Financial condition discovery seeks information about a defendant's assets and finances, typically in support of punitive damages.

Initial disclosures are the information parties must provide without a discovery request early in the case.

Insurance agreement disclosure is the mandatory production of applicable liability policies without a discovery request.

Interrogatories are written questions served on a party that must be answered in writing under oath within a set period.

Jurisdictional discovery is limited discovery into facts bearing on the court's jurisdiction over a party.

Meet and confer is the required good-faith conference between counsel to resolve a discovery dispute before seeking court intervention.

A mental examination is a court-ordered psychological or psychiatric evaluation of a party whose mental condition is in controversy.

A motion to quash asks the court to invalidate or modify a subpoena on grounds including burden, privilege, or scope.

Net worth discovery seeks a defendant's overall financial position as evidence bearing on the amount of punitive damages.

Non-party discovery obtains documents and testimony from persons and entities that are not parties to the action.

An objection to subpoena is a non-party's written response contesting a document subpoena without moving to quash.

An out-of-state subpoena seeks discovery from a person in a different state than where the action is pending.

Overbroad and unduly burdensome is the objection that a request exceeds proper scope or imposes disproportionate cost.

Phased discovery sequences discovery into stages, addressing threshold issues before broader inquiry.

Policy limits disclosure is the obligation to reveal applicable insurance coverage, required by rule in litigation and increasingly by statute pre-suit.

A product inspection protocol is the agreed procedure governing examination of a product in litigation.

Proportionality is the requirement that discovery be proportional to the needs of the case, weighing importance, amount in controversy, burden, and access...

A records subpoena seeks documents from a non-party without requiring a personal appearance.

Relevance in discovery means bearing on a party's claim or defense, a narrower standard than the pre-2015 subject matter test.

A request for admission asks a party to admit or deny specific facts or the genuineness of documents, narrowing what must be proven at trial.

A request for production requires a party to produce documents, electronically stored information, or tangible things for inspection and copying.

Reserve discovery seeks an insurer's internal case reserve figures, contested as reflecting evaluation rather than liability.

Rolling production delivers documents in successive volumes as review completes rather than in a single production.

A Rule 34 inspection permits entry onto property or examination of tangible items in another party's control.

A Rule 35 examination is a court-ordered physical or mental examination of a party whose condition is in controversy, available on a showing of good cause.

The scope of discovery defines what may be obtained, limited to nonprivileged matter relevant to a claim or defense and proportional to the needs of the case.

A site inspection examines the location where an incident occurred to document conditions and take measurements.

The specific objection requirement obligates a party to state discovery objections with particularity rather than generically.

A subpoena is a court-authorized command requiring a person to testify, produce documents, or permit inspection, and it is the primary tool for non-party...

A subpoena ad testificandum commands a non-party to appear and give testimony at a deposition, hearing, or trial.

A subpoena duces tecum commands a non-party to produce documents or tangible things.

The UIDDA simplifies obtaining subpoenas in one state for actions pending in another through a clerk-issued process.

A vehicle inspection examines a vehicle involved in a collision to document damage, mechanical condition, and electronic data.

Verification is the party's sworn attestation that interrogatory answers are true, distinguishing them from counsel's objections.

Written discovery objections are the stated grounds for declining to answer or produce in response to a request.