April 20th will be my one year anniversary in my position. I've learned a ton in the last year, but the one thing I've struggled the most with has been drafting discovery requests.
This week, I had a shortened deadline (due to an attorney vacation) to get out discovery requests in an exception to discharge bankruptcy adversary proceeding. I needed to draft: requests for admissions, interrogs, and requests for production.
The exception to discharge was based on falsified or erroneous financial statements provided to the lender on an agricultural line of credit. So where did I start? - I started with the false financial statements. Using the statements, I created a line of questioning relating to each claimed asset - including disposition of the asset, and created admissions centered around the sworn financial statements.
Ultimately, the associate attorney on the file and I sat down with one of the partners, he reviewed, and they were looking good. He taught me the most important part of drafting discovery requests - how to get to your questions.
Focus on your objective. What is the ultimate goal of the action? Then, look to the law. What elements do I need to meet? Review the facts for missing information. What am I missing to meet the elements on a factual basis? Finally, formulate your questions to obtain the missing information.
I wish I could elaborate more, but its time to unwind my tightly spun brain :)