Discovery – The Devices

In a civil litigation firm, the paralegal will be engaged much of the time in discovery, propounding it and responding to it.  The paralegal in training needs to learn all that he or she can about discovery and the various types of discovery devices.

In becoming familiar with discovery, it is important to know the parameters and requirements of the different discovery devices.  To begin with, you should focus on learning the following information about each device:

  • Name
  • On whom can it be served? (party or non-party)
  • What are the time limitations?
  • Are there other limitations?
  • What are the costs associated with this device?

This information is most easily found in an attorney practice guide or in the California Code of Civil Procedure sections 2016 et. seq.

The following are some of the more commonly used devices with which the California paralegal should definitely be familiar:

Interrogatories (Form and Special)

Demand for Inspection (or Production) of Documents


Request for Admissions

Subpoena for Business Records

Request for Physical or Mental Exam

Request for Exchange of Expert Witnesses

Look for future posts on each of the devices.


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