Especially when the number of interrogatories is limited by rule, as it is in Illinois, you should always consider alternative ways of obtaining the facts you seek in your initial discovery. Some alternative sources might be cheaper and more efficient; others might prevent you from having to reveal your litigation strategies so early in the case.
Your own client is an often-overlooked source of information. It's just one of many examples why you should think wisely before you send out that initial round of discovery.



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