STEPS:
1.   Click the Discovery screen from the Client Information folder on the Site Plan.   View screen shot.
2.   The Discovery screen is used to track timely receipt of answers from the defendant to the plaintiff's discovery, as well as track the plaintiff's responses to the discovery sent by the defendant.
3.   For example, for the defendant's discovery of the plaintiff, enter the following information using the Tab key on your keyboard to move between fields:
  • Discovery of  - to whom the discovery is directed (defendant's discovery of plaintiff or defendant's discovery of non-party).
  • Defendant - use the drop-down list to select the defendant who sent the discovery to the plaintiff.
  • Type of Discovery - use the drop-down list to select either interrogatories, request for production of documents, or request for admissions.
  • Recipient - from the drop-down list, select plaintiff, provider, or witness.
  • If the defendant is seekng discovery from a provider or witness, the corresponding Provider field or Witness fields have drop-down lists allowing you to select the appropriate case related provider or witness.
  • When the plaintiff receives the discovery, check the Received box and enter the date in the Date Received field.
  • The Due Date for the plaintiff's answer to the defendant's discovery is automatically calculated and set to 30 days from the date in the Date Received field.

4.   The following ticklers are set:

  • The day the discovery is received, send a motion for enlargement of time to respond to the defendant's discovery.  Use the EXTTIME letter.

  • Also on the day the discovery is received, send a letter with the discovery documents to the client.  Use the DDISC1 letter.

  • At a pre-determined number of days, currently set to 30, a tickler appears in the Daily Tickler and on the Daily Worksheet asking if you've sent the plaintiff's answers to the defendant's informal discovery.  If no, prepare the plaintiff's second motion for enlargement of time to respond to the defendant's discovery.   Use the EXTTIME2 letter.

  • If the plaintiff files for an extension, check the Extension Filed field.

  • Upon receipt of the order allowing the extension, manually input a new date in the Due Date field and check the Extension Granted box.

  • At a pre-determined number of days, currently set to 60, a tickler appears asking if we've sent the plaintiff's answers to the defendant's informal discovery.  If no, call the client about the discovery materials.
5.   Once the plaintiff's answer to the defendant's discovery is sent, check the Sent box and enter the date in the Date Sent field.
6.    The following ticklers occur in the Daily Tickler and on the Daily Worksheet:
  • Use the PDISC1 cover letter the day the plaintiff's discovery of the defendant is sent out.
  • At a pre-determined number of days, currently set at 40, a tickler appears on the Daily Tickler and Daily Worksheet asking if you've received the defendant's answers to the discovery or enlargement.  If yes, set up the necessary depositions.  If no, send the discovery request letter DISCOVR1.
  • At a pre-determined number of days, currently set at 70, a tickler appears on the Daily Tickler and Daily Worksheet asking if you've received the defendant's answers to the discovery or enlargement.  If yes, set up the necessary depositions.  If no, send the second discovery request letter DISCOVR2.
  • At a pre-determined number of days, currently set to 100, a tickler appears on the Daily Tickler and Daily Worksheet asking if you've received the defendant's answers to the discovery or enlargement.  If no, prepare a motion to compel discovery from the defendant using the MOTCOMPL document.  If yes, set up the necessary depositions.

 

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