Discovery request generator

Starting template only. This generates a general set of requests for the case type selected under standard federal rule numbering limits. Review, customize, and add case-specific requests before serving, and confirm your specific court's local rules and any applicable numerical limits. See our full disclaimer.

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A litigation consultant can help you refine these requests with case-specific facts, avoid overbroad objections, and stay within your court's local rule limits.

What's the difference between the 3 main types of written discovery?

Interrogatories are written questions the responding party must answer in their own words under oath, authorized by FRCP 33 and capped at 25 per party in federal court absent a stipulation or court order allowing more. Requests for production, authorized by FRCP 34, compel the other side to produce actual documents, electronically stored information, or tangible things, and carry no numerical limit under the federal rules. Requests for admission, authorized by FRCP 36, ask the other party to admit or deny specific statements, narrowing the issues that actually need to be proven at trial, and also carry no federal numerical limit.

All 3 types generally carry a 30-day response window in federal court, though this can be shortened or extended by court order or party agreement. Many cases use interrogatories to first identify the universe of relevant documents and witnesses, then follow up with targeted requests for production to actually obtain them. Once your discovery requests are drafted, our deposition outline generator helps prepare follow-up questioning once written discovery responses come back, and our case deadline calendar helps track the 30-day response window itself.

Do state courts follow the same interrogatory limits as federal court?

Not necessarily. Many states set their own numerical limits that differ from the federal 25-interrogatory cap, and some jurisdictions count subparts of a single interrogatory as separate interrogatories toward that limit, which can cause a seemingly compliant set of requests to actually exceed the cap. Always confirm your specific state and local court rule rather than assuming the federal limit applies.

Can requests for admission be used strategically to shorten a case for trial?

Yes, and this is one of their most valuable uses. A fact admitted in response to a request for admission is treated as conclusively established for the case, removing the need to prove it through other evidence at trial. Well-drafted requests for admission targeting undisputed or hard-to-deny facts can meaningfully narrow the issues that actually need to be litigated.

What happens if a party fails to respond to discovery requests within the deadline?

Consequences vary by discovery type. For requests for admission specifically, a matter is generally deemed admitted under FRCP 36(a)(3) if no timely response is served, which can be a serious and sometimes case-determinative consequence. For interrogatories and requests for production, a non-responding party typically faces a motion to compel, and continued non-compliance can lead to sanctions including adverse evidentiary rulings.

Frequently asked questions about discovery requests

Yes, common objections include that a request is overly broad, unduly burdensome, seeks privileged information, or isn't proportional to the needs of the case under FRCP 26(b)(1). An objection must state the specific grounds and generally can't be used to avoid responding entirely if only part of the request is objectionable, since the responding party must still answer or produce whatever isn't covered by the objection.

Generally yes if the subparts are discrete rather than logically related to the primary question, which is a frequent source of dispute between parties. Courts often look at whether each subpart could stand alone as a separate question to decide whether it counts separately toward the numerical limit.

No, requests for production only compel production of documents that exist and are within the responding party's possession, custody, or control at the time of the request, or that come into existence during an ongoing duty to supplement responses. They can't compel creation of a new document that doesn't already exist.

Yes, under FRCP 36(b), a court may permit withdrawal or amendment of an admission if it would promote presenting the case on the merits and the requesting party wouldn't be prejudiced by relying on the admission. This isn't automatic and requires court approval, so an admission shouldn't be treated as easily reversible.

Yes, generic discovery requests that don't connect to the specific claims and defenses at issue are more likely to draw objections and less likely to produce useful information. Discovery must also be proportional to the needs of the case under FRCP 26(b)(1), so overly broad or boilerplate requests unrelated to the actual dispute risk being challenged or limited by the court.