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Family Law Solutions
Training Library



Discovery

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Discovery Overview – Rules, Requests & Managing the Process (Course ID 1039)

Learn the purpose and rules of discovery, how to draft informal discovery requests, serve discovery properly, manage deadlines, prepare a discovery chart, and request mandatory disclosures from clients.

 

Forms Included:

  • Informal Discovery Request Letter

  • Rule 5.2 Certificate of Service

  • Discovery Chart

  • Mandatory Discovery Instructions to Client

  • Required Documents to Be Produced

  • Mandatory Interrogatories

  • Request for Supplementation

 

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Issuing Discovery to Parties – Interrogatories, Document Production & Requests for Admission (Course ID 1040)

This class focuses on drafting Interrogatories, Requests for Production of Documents, and Requests for Admission for both divorce and modification cases. You will also learn when to limit discovery to trial preparation.

 

Forms Included:

  • Notice to Produce and Request for Production of Documents – Divorce

  • Notice to Produce and Request for Production of Documents – Modification

  • Notice to Produce (limited for trial)

  • Interrogatories – Divorce

  • Interrogatories – Modification

  • Requests for Admission to Opposing Party – Divorce

 

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Responding to Discovery – Protecting Clients & Meeting Deadlines (Course ID 1041)

Learn how to respond to discovery requests clearly and on time. This class covers drafting responses to Interrogatories, Requests for Production of Documents, and Requests for Admission, and includes sample client instructions for gathering information.

 

Forms Included:

  • Discovery Instructions to Client

  • Objections and Responses to Interrogatories

  • Objections and Responses to Request for Production of Documents

  • Objections and Responses to Requests for Admission

 

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Issuing Discovery to Non–Parties – Document Production & Subpoenas (Course ID 1042)

This class teaches how to obtain documents and testimony from non–parties through subpoenas, depositions, and requests for production, including drafting service letters, handling failures to produce, and pursuing attorney’s fees when appropriate.

 

Forms Included:

  • Deposition Subpoena

  • Subpoena for Production of Documents

  • Service Letter

  • Out–of–State Deposition Subpoena

  • Application for Issuance of Out–of–State

  • Service Letter

  • Request for Production of Documents to Non–Party

  • Cover Letter

 

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Depositions – Scheduling, Noticing & Preparing (Course ID 1043)

This class walks through how to schedule, notice, and prepare for depositions. You’ll draft a Notice of Taking Deposition (party and non–party), Subpoena for Deposition, cover letter, and learn how to prepare a deposition outline and request documents from non–parties.

 

Forms Included:

  • Notice of Taking Deposition – Party

  • Subpoena for Deposition

  • Notice of Taking Deposition of Non–Party

  • Cover Letter to Deposition Witness

  • Request for Production of Documents to Non–Party

  • Cover Letter to Deposition Witness

  • Affidavit of Authenticity

 

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Discovery Disputes – Enforcing Compliance & Involving the Court When Necessary (Course ID 1044)

When discovery responses are late, incomplete, or ignored, disputes arise. This class covers Rule 6.4(B) good–faith letters, drafting Motions to Compel, Notices of Discovery Dispute, Orders to Compel, and Motions for Contempt and Sanctions.

 

Forms Included:

  • 6.4(B) Letter – No Response

  • 6.4(B) Letter – Attaching Discovery Chart

  • 6.4(B) Letter – Deficient Response

  • Letter – Counting Interrogatories

  • Fulton County Notice of Discovery Dispute

  • Motion to Compel

  • Order Granting Motion to Compel

  • Motion for Contempt and to Strike Pleadings

 

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