Thinking Outside the Box
Why wait for the opposing party to send you discovery requests? In those instances when you know what the relevant issues are and you have the information in hand, why wait for the other side to request it? Often we will send our client's pertinent medical records and expenses as soon as we learn the identity of defense counsel in a personal injury or medical malpractice case. In a vehicle accident case we may send the police report. At least one lawyer in our office has even been known to send the defendant completed discovery responses before the defense lawyer got around to serving any discovery requests. The point is, if you want to keep the case moving, and you know eventually you will be sharing the information anyway, why not do it sooner rather than later?