LibGuides: Resources for Litigators: Discovery

Discovery Strategies

Art of Advocacy - Discovery
See Part I for an overview. Part V offers samples of combined discovery where different discovery tools are combined into one request (interrogatories, request for admission, request for production etc.) Part VII offers additional Model Discovery
Art of Advocacy: Preparation of the Case
See Chapter 5: Gathering the Evidence for a discussion of discovery tools along with how to gather and preserve evidence.
Discovery Practice
See Chapter 8: Discovery Strategies for tips on creating a discovery plan, information about discovery sequence and timing and other issues.
Discovery Strategy (Pennsylvania-PBI)
Pennsylvania-specific. Available in print on 3rd Floor: KFP 537 .A75 .D572 2013
Discovery Proceedings in Federal Court
See Part One. General Discovery Procedure
Federal Litigation Guide (Lexis)
See CHAPTER 9 The Purposes of Discovery, CHAPTER 10 Planning and Preparation for Discovery and CHAPTER 11 Discovery and Interim Injunctive Relief
KeyRules
Locate KeyRules for your jurisdiction (if they exist--not available for every jurisdiction) and look for the Requests, Notices and Applications section to find guidance for each type of discovery tool.
LexisNexis Practice Guide New Jersey Civil Discovery
See Chapter 1: Planning Discovery
LexisNexis Practice Guide: Pennsylvania Civil Discovery
See the Master Checklist for Pennsylvania Civil Discovery, Chapter 1 PLANNING DISCOVERY and Chapter 2 TIMING OF DISCOVERY. Also note that the individual chapters covering different discovery devices all include a "strategy" section at the beginning.
LexisNexis Practice Guide: Pennsylvania Civil Pretrial Practice
See Chapter 5 DISCOVERY GENERALLY
Litigating Tort Cases
Reviews all types of discovery tools including checklists and sample forms
Standard Pennsylvania Practice 2d
See Chapter 34. Discovery and Depositions, Generally

Affirmative/Initial Disclosures & Precomplaint Discovery

Discovery Practice
See Chapter 2, Disclosures. Walks through the different types of initial disclosures provided for under the federal rules.

Chapter 9 deals with Precomplaint discovery provided for under Federal Rule 27.
Gibbons on Federal Practice in New Jersey (NJICLE)
New Jersey continuing education program handbook. See Chapter 3 Case Management and Discovery

Interrogatories

Art of Advocacy - Discovery
See Part III: Interrogatories and Requests for Production of Documents. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. Part VII offers additional Model Discovery.
Art of Advocacy: Preparation of the Case
See Chapter 5: Gathering the Evidence for a discussion of discovery tools along with how to gather and preserve evidence.
Bender's Forms of Discovery Interrogatories (Volumes 1 to 10A)
Sample interrogatories for many, many different types of cases organized alphabetically by topic. Offers interrogatories for both plaintiff and defense and each set of interrogatories features a summary of the topics covered by the questions along with the numbers of the questions that relate to that topic. Appendix offers Uniform Interrogatories and the jurisdictions that suggest or require they be used (including PA, NJ & DE)
Litigating Tort Cases
Reviews all types of discovery tools including checklists and sample forms
Practical Law--Discovery & Evidence
Sort through practice notes and sample documents. Limit by jurisdiction filter and add key words to locate specific types of documents and discovery tools.
Trial Court Documents--Interrogatories
Limit by case type or by party type and can enter keywords. Once click search can further limit by jurisdiction.

Cyclopedia of Federal Procedure (Westlaw)
See Part II, Chapter 25: Depositions and Discovery
Discovery Practice
See Chapters 21- 23 on drafting and responding to interrogatories.
Discovery Proceedings in Federal Court
See Part Three. Interrogatories
Federal Civil Procedure Litigation Manual
See TITLE V. DISCLOSURES AND DISCOVERY for commentary on the Federal Rules addressing discovery.
Federal Litigation Guide
See CHAPTER 12 Interrogatories
Fundamentals of Litigation Practice
See Part 3, Chapter 17. Interrogatories
Handbook of Federal Civil Discovery & Disclosure
Expert commentary and an appendix of forms.

Discovery--West's Pennsylvania Practice
See Chapter 3. Interrogatories and Chapter 4. Tactical Considerations in the Use of Interrogatories in the Discovery Plan
LexisNexis Practice Guide: Pennsylvania Civil Discovery
See Chapter 3 INTERROGATORIES; Appendix has sample interrogatories and sample objections.
LexisNexis Practice Guide: Pennsylvania Civil Pretrial Practice
See Chapter 6 WRITTEN DISCOVERY; Appendix includes sample interrogatories
Practical Law--Discovery & Evidence
Filtered to limit to PA only. Sort through practice notes and sample documents. Add key words to locate specific types of documents and discovery tools.
Standard Pennsylvania Practice 2d
See Chapter 35. Written Interrogatories
West's Pennsylvania Forms
See Civil Procedure, Part X. Discovery, Chapter 40. Interrogatories

Civil Practice Forms--New Jersey (Westlaw)
See Chapters 37 - 39: Interrogatories, Uniform Interrogatories and Sample Interrogatories.
Court Rules Annotated--New Jersey Practice Series (Westlaw)
See Part IV, Chapter III: Rules 4.17
Discovery--New Jersey Practice Series (Westlaw)
See Chapter 2 Interrogatories. Appendix to this chapter includes numerous sample interrogatories for various case types.
Gibbons on Federal Practice in New Jersey (NJICLE) (Lexis)
New Jersey continuing education program handbook. See Chapter 3 Case Management and Discovery
LexisNexis Practice Guide New Jersey Civil Discovery (Lexis)
See Chapter 2 INTERROGATORIES; Appendix has sample documents

Requests for Production

Art of Advocacy - Discovery
See Part III: Interrogatories and Requests for Production of Documents. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. Part VII offers additional Model Discovery.
Art of Advocacy: Preparation of the Case
See Chapter 5: Gathering the Evidence for a discussion of discovery tools along with how to gather and preserve evidence.
Litigating Tort Cases
Reviews all types of discovery tools including checklists and sample forms

Cyclopedia of Federal Procedure (Westlaw)
See Part II, Chapter 25: Depositions and Discovery
Discovery Practice
See Chapters 24-28:Document Production Procedures, Requesting Documents and Responding to Requests, Information from Nonparties, Requesting Specific Information: Computer Data and Tests, and Document Destruction (and Fabrication)
Discovery Proceedings in Federal Court
See Part Four. Other Discovery Methods
Federal Civil Procedure Litigation Manual
See TITLE V. DISCLOSURES AND DISCOVERY for commentary on the Federal Rules addressing discovery.
Federal Litigation Guide
See CHAPTER 13 Production of Documents, CHAPTER 14 Responding to Document Requests and CHAPTER 15 Management of Documents
Fundamentals of Litigation Practice
See Part 3, Chapter 18. Requests for Production of Documents and Things
Gibbons on Federal Practice in New Jersey (NJICLE)
New Jersey continuing education program handbook. See Chapter 3 Case Management and Discovery
Handbook of Federal Civil Discovery & Disclosure
Expert commentary and an appendix of forms.

Discovery--West's Pennsylvania Practice
See Chapter 5. Production of Documents and Things and Entry for Inspection and Other Purposes
LexisNexis Practice Guide: Pennsylvania Civil Discovery
See Chapter 4 REQUESTS FOR PRODUCTION OF DOCUMENTS FOR INSPECTION; Appendix offers sample forms
LexisNexis Practice Guide: Pennsylvania Civil Pretrial Practice
See Chapter 6 WRITTEN DISCOVERY; Appendix includes sample notices to produce, subpoenas and other requests for production
Standard Pennsylvania Practice 2d
See Chapter 36. Production and Inspection of Documents and Other Property
West's Pennsylvania Forms
See Civil Procedure, Part X. Discovery, Chapter 41. Production of Documents and Things and Entry for Inspection and Other Purposes

Civil Practice Forms--New Jersey (Westlaw)
See Chapter 40: Documents and Property
Court Rules Annotated--New Jersey Practice Series (Westlaw)
See Part IV, Chapter III: Rule 4.18
Discovery--New Jersey Practice Series (Westlaw)
See Chapter 3: Production of Documents and Things; Entry Upon Land. Appendix contains sample requests, orders, notices, authorizations, protective orders and other documents.
LexisNexis Practice Guide New Jersey Civil Discovery (Lexis)
See Chapter 3 REQUESTS FOR PRODUCTION OF DOCUMENTS AND REQUESTS FOR ADMISSIONS; Appendix has sample documents

Requests for Admission

Art of Advocacy - Discovery (Lexis)
See Part IV: Requests for Admissions. Offers samples from several different case types. Part VII offers additional Model Discovery.
Art of Advocacy: Preparation of the Case
See Chapter 5: Gathering the Evidence for a discussion of discovery tools along with how to gather and preserve evidence.
Litigating Tort Cases
Reviews all types of discovery tools including checklists and sample forms

Cyclopedia of Federal Procedure (Westlaw)
See Part II, Chapter 25: Depositions and Discovery
Discovery Practice (Westlaw)
See Chapter 30: Requests for Admissions
Discovery Proceedings in Federal Court (Westlaw)
See Part Four. Other Discovery Methods
Federal Civil Procedure Litigation Manual
See TITLE V. DISCLOSURES AND DISCOVERY for commentary on the Federal Rules addressing discovery.
Federal Litigation Guide
See CHAPTER 19 Requests to Admit
Fundamentals of Litigation Practice
See Part 3, Chapter 21. Requests for Admissions
Handbook of Federal Civil Discovery & Disclosure
Expert commentary and an appendix of forms.

Discovery--West's Pennsylvania Practice
See Chapter 13. Requests for Admission
LexisNexis Practice Guide: Pennsylvania Civil Discovery
See Chapter 11 REQUESTS FOR ADMISSION; Appendix has sample documents
LexisNexis Practice Guide: Pennsylvania Civil Pretrial Practice (Lexis)
See Chapter 6 WRITTEN DISCOVERY
Standard Pennsylvania Practice 2d
See Chapter 34. Discovery and Depositions, Generally
West's Pennsylvania Forms
See Civil Procedure, Part X. Discovery, Chapter 44. Request for Admission

Civil Practice Forms--New Jersey (Westlaw)
See Chapter 42: Admission of Facts and of Genuineness of Documents
Court Rules Annotated--New Jersey Practice Series (Westlaw)
See Part IV, Chapter III: Rule 4.22
Discovery--New Jersey Practice Series (Westlaw)
See Chapter 6: Requests for Admission. Chapter appendix includes sample requests, notices, orders and checklists.
LexisNexis Practice Guide New Jersey Civil Discovery (Lexis)
See Chapter 3 REQUESTS FOR PRODUCTION OF DOCUMENTS AND REQUESTS FOR ADMISSIONS; Appendix has sample documents

Requests for Physical, Mental, or Land Examinations

Art of Advocacy - Discovery (Lexis)
Does not discuss Requests for Examination in detail but does provide Model Discovery requests in Part VII.
Art of Advocacy: Preparation of the Case (Lexis)
See Chapter 5: Gathering the Evidence for a discussion of discovery tools along with how to gather and preserve evidence.

Cyclopedia of Federal Procedure (Westlaw)
See Part II, Chapter 25: Depositions and Discovery
Discovery Practice (Westlaw)
See Chapter 29: Physical Examinations
Discovery Proceedings in Federal Court (Westlaw)
See Part Four. Other Discovery Methods
Federal Civil Procedure Litigation Manual
See TITLE V. DISCLOSURES AND DISCOVERY for commentary on the Federal Rules addressing discovery.
Federal Litigation Guide
See CHAPTER 20 Inspection of Land and Other Tangibles and CHAPTER 21 Physical and Mental Examinations
Fundamentals of Litigation Practice
See Part 3, Chapter 20. Physical Examinations
Handbook of Federal Civil Discovery & Disclosure
Expert commentary and an appendix of forms.

Discovery--West's Pennsylvania Practice
See Chapter 6: Physical and Mental Examination of Persons and Chapter 5. Production of Documents and Things and Entry for Inspection and Other Purposes
LexisNexis Practice Guide: Pennsylvania Civil Pretrial Practice
See Chapter 6 WRITTEN DISCOVERY
Standard Pennsylvania Practice 2d
See Chapter 37. Physical and Mental Examination of Persons & Chapter 36. Production and Inspection of Documents and Other Property
West's Pennsylvania Forms
See Civil Procedure, Part X. Discovery, Chapter 41. Production of Documents and Things and Entry for Inspection and Other Purposes and Chapter 43. Physical and Mental Examination of Persons

Civil Practice Forms--New Jersey (Westlaw)
See Chapter 41: Physical and Mental Examinations of Persons
Court Rules Annotated--New Jersey Practice Series (Westlaw)
See Part IV, Chapter III--Rule 4.19
Discovery--New Jersey Practice Series (Westlaw)
See Chapter 5 for Physical and Mental Examination of Persons. See appendix for this chapter for sample letters, notices and certifications.

Depositions

Advanced Deposition Techniques (PLI PLUS)
Annual CLE course handbook. Browse using Table of Contents or Index. Prior year editions available on the "Related Items" tab along with transcripts of the course.

Art of Advocacy - Discovery
See Part II Depositions for sample questions related to various types of cases including motor vehicle accidents, premises liability, medical malpractice and others. Part VII offers additional Model Discovery
Art of Advocacy: Preparation of the Case
See Chapter 5: Gathering the Evidence for a discussion of discovery tools along with how to gather and preserve evidence.

Cross-Examination for Depositions (Lexis)
Discusses purposes of deposition, preparing for deposition, using documents during depositions and making objections. Much of this treatise covers questioning techniques and methods.
Depositions: Procedure, Strategy & Technique (Westlaw)
Covers preparing for and carrying out the deposition from both the deposing attorney and the defending attorney perspectives and how to use depositions at trial. Appendix includes state and federal deposition practice rules. Updated annually.
Fundamentals of Taking and Defending Depositions (PLI PLUS)
Annual CLE course handbook covering variety of topics. Browse using Table of Contents or Index. Prior editions available on the "Related Items" tab along with transcripts from the course.
Litigating Tort Cases
Reviews all types of discovery tools including checklists and sample forms
Pattern Deposition Checklists (Westlaw)
Describes mechanics of and preparation for depositions but also gives sample questions for different types of cases (both plaintiff and defense)
Questioning Techniques & Tactics (Westlaw)
See Chapter 7. The Deposition: Additional Principles and Considerations

Cyclopedia of Federal Procedure
See Part II, Chapter 25: Depositions and Discovery

Deposition Resource Kit (Federal) [Practical Guidance]
Practice notes, checklists and forms for how to notice, prepare for, and take and defend depositions of parties, nonparties, and expert witnesses in federal cases.

Deposition Rules: The Essential Handbook to Who, What, When, Where, Why and How (Lexis)
Published by NITA (National Institute of Trial Advocacy), this practice guides acts like a frequently asked questions page about depositions. It's not very conducive to browsing but does give practice tips and cites to federal rules and case law.
Discovery Practice (Westlaw)
See Chapters 16-20 for information on preparing for and taking depositions as well as using the deposition at trial.
Discovery Proceedings in Federal Court (Westlaw)
See Part Two. Depositions
The Effective Deposition: Techniques and Strategies That Work (Lexis)
Cites to federal rules and case law, walks through taking and defending depositions and has a section on "mechanics" that deals with noticing, compelling witnesses to attend and other issues. Appendices include sample notices, questions and other documents.
Federal Civil Procedure Litigation Manual
See TITLE V. DISCLOSURES AND DISCOVERY for commentary on the Federal Rules addressing discovery.
Federal Litigation Guide
See Chapters 16 - 18 on preparing, taking and defending depositions.
Fundamentals of Litigation Practice
See Part 3, Chapters 14 - 16.
Handbook of Federal Civil Discovery & Disclosure
Expert commentary and an appendix of forms.

The A to Z of Civil Depositions in Pennsylvania
PBI Press. In print on 3rd Floor: KFP 537 .C66 2012

Deposition Resource Kit (PA) [Practical Guidance]
Practice notes, forms and checklists related to how to notice, prepare for, take, and defend depositions of parties and nonparties in Pennsylvania.

Discovery--West's Pennsylvania Practice
See Chapter 7. Depositions, Chapter 8. Videotape Depositions, Chapter 9. Deposition Procedures, Chapter 10. Deposition Objections and Chapter 12. Use of Depositions at Trial
LexisNexis Practice Guide: Pennsylvania Civil Discovery
See Chapter 5 DEPOSITIONS & Chapter 8 THIRD-PARTY DISCOVERY; Appendix contains sample notices and orders
LexisNexis Practice Guide: Pennsylvania Civil Pretrial Practice (Lexis)
See Chapter 7 DEPOSITIONS
Practical Law--Discovery & Evidence
Filtered to limit to PA only. Sort through practice notes and sample documents. Add key words to locate specific types of documents and discovery tools.
Standard Pennsylvania Practice 2d
See Chapter 34. Discovery and Depositions, Generally
Taking and Defending Depositions (PBI)
Pennsylvania-specific. In print on 3rd Floor: KFP 537 .A75 .T34 2015
West's Pennsylvania Forms
See Civil Procedure, Part X. Discovery, Chapter 42. Depositions

Civil Practice Forms--New Jersey (Westlaw)
See Chapters 32-36: Depositions During Action, Depositions—Objections and Limitations, Depositions before Action, Pending Appeal, or for Use in Other Jurisdictions, Depositions in Foreign Countries, and Depositions on Written Questions.
Court Rules Annotated--New Jersey Practice Series (Westlaw)
See Part IV, Chapter III: Rules 4.10 - 4.16 govern depositions
Court Rules Annotated - Trial Lawyers--New Jersey Practice Series (Westlaw)
See Chapter 2 Part B, Preparing Depositions for Use at Trial

Deposition Resource Kit (NJ) [Practical Guidance]
Practice notes, forms, and checklists for how to notice, prepare for, take, and defend depositions of parties and nonparties in New Jersey courts.

Discovery--New Jersey Practice Series (Westlaw)
See Chapter 4: Depositions. Appendix to this chapter includes sample orders, notices and subpoenas.
Gibbons on Federal Practice in New Jersey (NJICLE)
New Jersey continuing education program handbook. See Chapter 3 Case Management and Discovery
LexisNexis Practice Guide New Jersey Civil Discovery (Lexis)
See Chapters 4 & 5 and Appendix for notices, orders and other sample documents related to depositions.

Privileges, Objections to Discovery and Refusal to Make Discovery

Destruction of Evidence (Westlaw)
Discussion of laws surrounding routine and deliberate destruction of evidence including discovery sanctions.
Discovery Practice (Westlaw)
See Chapter 2, Disclosures. Walks through the different types of initial disclosures provided for under the federal rules.

Chapter 9 deals with Precomplaint discovery provided for under Federal Rule 27.

Cyclopedia of Federal Procedure (Westlaw)
See Part II, Chapter 25: Depositions and Discovery
Discovery Practice (Westlaw)
See Chapters 10 - 15 for a discussion of various types of privileges that may be claimed under the federal rules. And Chapter 28 on Document Destruction, Chapter 31: Sanctions and Enforcement of Discovery Rights and Chapter 32: Discovery Ethics and Malpractice.
Discovery Proceedings in Federal Court (Westlaw)
See Part Five. Limiting and Enforcing Discovery Obligations
Federal Civil Procedure Litigation Manual
See TITLE V. DISCLOSURES AND DISCOVERY for commentary on the Federal Rules addressing discovery.
Federal Litigation Guide
See CHAPTER 9 The Purposes of Discovery, CHAPTER 22 Enforcement of Discovery and CHAPTER 26 Conduct and Demeanor of Attorneys
Fundamentals of Litigation Practice
See Part 3, Chapter 12 Discovery Planning and Limitations and Chapter 22 Enforcing Discovery Rights
Handbook of Federal Civil Discovery & Disclosure
Expert commentary and an appendix of forms.

Discovery--West's Pennsylvania Practice
See Chapter 2. Evidence Beyond the Scope of Discovery (coverage of different types of privilege)
LexisNexis Practice Guide: Pennsylvania Civil Discovery
See Chapter 9 OBJECTIONS TO DISCOVERY & Chapter 10 SANCTIONS FOR FAILURE TO PRODUCE DISCOVERY OR FOR SPOLIATION. Appendix includes sample privilege log
LexisNexis Practice Guide: Pennsylvania Civil Pretrial Practice
See Chapter 8 DISCOVERY MOTIONS AND ORDERS
Practical Law--Discovery & Evidence
Filtered to limit to PA only. Sort through practice notes and sample documents. Add key words to locate specific types of documents and discovery tools.
West's Pennsylvania Forms
See Civil Procedure, Part X. Discovery, Chapter 46. Limitations on the Scope of Discovery and Chapter 47. Sanctions

Civil Practice Forms--New Jersey (Westlaw)
See Chapter 43: Refusal or Failure to Make Discovery. Discusses consequences and remedies for unmet discovery broken down by type of discovery tool at issue.
Court Rules Annotated--New Jersey Practice Series (Westlaw)
See Part IV, Chapter III: Rule 4.23 Failure to Make Discovery; Sanctions
Discovery--New Jersey Practice Series (Westlaw)
See Chapter 7: Failure to Make Discovery; Enforcement and Sanctions
LexisNexis Practice Guide New Jersey Civil Discovery (Lexis)
See Chapter 7 OBJECTIONS TO DISCOVERY, Chapter 8 EXTENSION OF DISCOVERY DEADLINES and Chapter 9 DISCOVERY MOTIONS

Understanding Discovery Received

Annotated Reference Manual on Scientific Evidence
Offers guides to help understand different types of evidence, usually as presented by experts. Includes: statistics, epidemiology, toxicology, engineering, medical testimony and others.

Attorneys Medical Advisor (Westlaw)
Easy to read descriptions of medical disorders, injuries and other issues. Useful for understanding injuries, damages associated with those injuries or conditions and expert reports related to those medical issues.
Attorneys Medical Deskbook (Westlaw)
Useful for cases involving personal injury, medical malpractice, wrongful death, and workers' compensation. Discusses uses and side affects of drugs, defines medical terms and abbreviations, explains medical and diagnostic tests and imaging and offers guidance for interpreting medical records.
LexisNexis Practice Guide New Jersey Civil Discovery (Lexis)
See Chapter 10 USE OF DISCOVERED MATERIAL AT TRIAL

eDiscovery Resources

Arkfeld's Best Practices Guide for ESI Pretrial Discovery by Michael R. Arkfeld
Call Number: Lexis+
Publication Date: Updated annually
Offers overview of electronic discovery as well as how to prepare an electronic discovery plan and strategy, discussion of issues and how discovery should be handled in each stage of litigation

eDiscovery by David Ries/PBI
Call Number: 3rd Floor: KF8902 .E42 .E45 2017
Publication Date: 2017
eDiscovery Response Planning: A Guide for Corporate Legal Departments by SAM PANARELLA and PRASHANT DUBEY
Call Number: Lexis Advance
Publication Date: Updated annually
Electronic Discovery (Lexis)
Call Number: Lexis Advance
Publication Date: Current
Data collection, preserving evidence, drafting discovery requests, deposing data managers and other issues.
Federal Litigation Guide by JENNER & BLOCK, LLC
Call Number: Lexis Advance
Publication Date: Updated twice annually
See CHAPTER 24 Discovery of Computer-Based Information
eDiscovery & Digital Evidence by Jay E. Grenig, William C. Gleisner, III
Call Number: Westlaw
Also see Appendix for sample forms
Electronic Discovery: Law and Practice (CCH) by Adam I. Cohen and David J. Lender of Weil, Gotshal & Manges, LLP
Call Number: Westlaw
No Table of Contents for browsing but can keyword search

Specialized Resources

Deskbook on the Management of Complex Civil Litigation (Lexis)
See Chapter II, Part 2 D for discovery issues.
Discovery--West's Pennsylvania Practice
See Chapter 11. Foreign Discovery
Discovery in Construction Litigation (Lexis)
Walks through different discovery tools and offers advice for handling discovery in different types of claims such as construction defect, federal contractor cases, and discovery in delay and disruption cases.

Discovery Motions Resource Kit (Federal) [Practical Guidance]
Practice notes, forms and checklists providing an overview of discovery-related motions in federal litigation, including motions to compel discovery, motions to quash a subpoena, motions for a protective order, and motions for discovery sanctions. Also provides guides to select districts’ local rules requirements for discovery motions.

Expert Testimony: A Guide for Expert Witnesses and the Lawyers Who Examine Them (Lexis)
See Chapter 4: Discovery and Depositions
Federal Litigation Guide
See CHAPTER 23 Discovery of Experts
Handbook of Personal Injury Forms & Litigation Materials
See Chapter 3 Formal Discovery
LexisNexis Practice Guide: Pennsylvania Civil Discovery (Lexis)
See Chapter 6 MEDICAL DISCOVERY & Chapter 7 EXPERTS
Handling Motor Vehicle Accident Cases: Treatise & Forms, 2d
See Chapter 7. Discovery and Pre-Trial Preparation
Pattern Discovery: Employment Discrimination (Westlaw)
Sample interrogatories, requests for production and deposition questions.