Discovery is frustrating because other litigants and lawyers often ignore discovery deadlines or provide incomplete answers. One is then faced with the expense and delay of filing a Motion to Compel. One trick that sometimes works to get documents is to schedule a deposition and simply request the party to bring the documents to the deposition that have been requested by Request for Production. While the party could simply ignore it just like the request, the fact that the Party is going to be faced with producing the documents on a specific date sometimes works. Attorneys should simply get in the habit of incorporating their request for documents in their notice of deposition.
