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Written Discovery Toolkit (IL)
Practical Law Toolkit w-041-1953 (Approx. 6 pages)
Resources to assist counsel with drafting, serving, objecting to, and responding to written discovery requests in Illinois circuit court civil litigation. Specifically, this Toolkit includes resources about interrogatories, requests for the production of documents (RFPs) (also called document requests), requests for admission (RFAs), and subpoenas.
Parties use various devices to obtain discovery during the pretrial phase of civil litigation. Written discovery generally includes:
- Requests for admission (RFAs).
- Requests for the production of documents (RFPs) (also called document requests).
Illinois has liberal discovery rules that allow broad discovery of any matter that is relevant to the pending action, including all claims and defenses, or any matter that leads to the discovery of admissible evidence. A party may obtain through discovery full disclosure of all non-privileged materials and communications. (Ill. S. Ct. R. 201(b)(1); Ill. S. Ct. R. 216; see also Redelmann v. Claire Sprayway, Inc., 375 Ill. App. 3d 912, 927 (2007).)
Counsel use the information and documents they obtain in written discovery to:
- Draft supplemental discovery requests.
- Move to compel discovery.
- Prepare for depositions.
- File or oppose summary judgment motions.
- Inform settlement discussions.
- Prepare for trial.
This Toolkit offers links to resources explaining written discovery devices and how to draft, serve, object, and respond to written discovery in civil actions pending in Illinois circuit court.
For more on Illinois courts, see Practice Note, Illinois State Court Structure. For information on depositions in Illinois state court, see Practice Note, Depositions: Noticing a Deposition (IL).