What are best practices for drafting ROGs and RFAs?

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Copy copy copy (within reason). Everything in this job has been done before. Find some good examples to use as a template and make substitutions as needed. Check local rules/cases about ROGs with subparts - some courts will treat them as individual requests counting against your total, some won’t. One caveat about copying - when responding to written discovery, nix the boilerplate objections firms have been using for years. They won’t fly anymore. Narrowly tailor your objections in each response.

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This may be basic, but instruction/definitions for almost all terms/phrase repeated are key. It’s easier to say “no, this isn’t vague - look at my definition it’s clearly limited to X, which is obviously relevant to the claims and defenses at issue.”

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Step 1: Elements of the causes of action Step 2: What do you NEED to win? Step 3: Draft specific and narrowly tailored discovery requests based on the above. Sure, go ahead and look at other discovery requests as a reference, but I have been taught that each discovery request should be drafted specifically toward Step 2. Also, in regard to quantity, you use only as many as you need. How will you know how many you need? As many needed to achieve Step 2.

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Limit interrogatories to two things - who, what, when, where questions that provide basic info that you need for your investigation or to prepare for depos, and, at the end of the discovery period, contention interrogatories that are carefully crafted to lock down your adversary’s positions for trial. All other rogs are a waste of time. I don’t use RFAs much except as part of my late discovery contention interrogatories. Too few judges are willing to force answers on meaningful issues. As a result I rarely get a RFA response that is useful in any way, shape, or form.

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I mainly use RFAs for document authentication. I rarely get a substantive response to anything else.

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The above comment is great. I have a similar suggestion. I use the uniform jury instructions to draft my discovery requests. They tend to provide a basic outline of what you need. I then try to fill in from there to make sure I get a complete picture.

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Thanks for that A1 and TL1. Good stuff!

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Can someone give me perspectives on this? PA used to be attractive despite low pay high hours due to its fast path (promotions) & fringe benefit like work from home, parental leave, ect. (To be cont)

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EY moves to unlimited PTO and adds a bunch more holidays. Your move, KPMG. ❤️❤️❤️

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Do club lounges at the Ritz include complementary cocktails? My guess is no.

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