Interrogatories and document requests
Interrogatories are written questions that the opposing party must answer under oath within 30 days. They are cheap to serve and useful for obtaining factual admissions, the opponent's legal theories, and names of witnesses. However, interrogatories are limited in number (typically 25 unless by agreement or court order) and cannot probe mental impressions or attorney strategy. The responding party can object on grounds of irrelevance, privilege, or undue burden.
Document requests compel the other side to produce all documents relevant to the case. These can be specific (requesting a particular contract) or broad (all documents relating to the subject matter of the suit). The scope is broader than interrogatories, but parties can withhold documents protected by attorney-client privilege or attorney work product, provided they assert the privilege in a privilege log that describes the withheld document.
Depositions and admissions
Depositions are oral examinations where a witness is questioned under oath by the opposing attorney, with a court reporter transcribing the testimony. Depositions are expensive but powerful tools for locking in testimony, assessing credibility, and obtaining detailed information. Parties can depose any person with relevant knowledge, not just the opposing party, and can use deposition testimony at trial if the witness is unavailable.
Requests for admission ask the other party to admit or deny specific facts or the genuineness of documents. Unlike interrogatories, these are cheap and focused on disputed facts. If a party fails to respond or denies an admission, the requesting party can move to compel or present the fact to the jury at trial. Admissions admitted to are binding and cannot be contradicted at trial, making this tool crucial for narrowing disputes before trial.