This packet includes a template for two types of thorough Interrogatories (Rogs) and Requests for Production (RFPs) which I use to get as much information and documents and answers from the other side, without having to do an expensive deposition. One is 74 pages long with 162 questions, the other is 72 pages with 194 questions. Also included is a template for Requests for Admissions (RFAs). Many attorneys say that discovery is THE GREATEST TOOL in any court case to get information and to prepare for hearings, especially for a full-blown trial. So, I'm always shocked when I hear of an attorney who doesn't even attempt any form of discovery.