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Act 53: I File My Discovery Requests

Discovery, I've learned, is the process by which you find out about your opponent's case. You ask them questions, they send you answers; you ask them to produce documents, they make copies and mail them to you. It's a two-way street – not only do I get to find out about Taubman's case, they get to find out about mine.

At least, that's the way the discovery process is supposed to work, in theory. I've never been involved in a lawsuit before, so I don't know if it's really that cut-and-dried or if, like everything else in this case, it will turn out to be more complicated and convoluted than I could possibly have imagined.

The judge gave us until February 15, 2002, to complete discovery – and from what I've read, I have to give Taubman at least 30 days to respond. And so, on January 2, 2002, I FedEx'ed the following set of discovery requests to Taubman. (If the writing does not appear to be my style, it's because Paul Levy, the Public Citizen attorney who's handling my appeal, wrote the first draft of this document for me to edit and submit.)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

THE TAUBMAN COMPANY )

LIMITED PARTNERSHIP, )

)

Plaintiff, )

) Civil Action No. 01-72987

v. )

) Honorable Lawrence P. Zatkoff

WEBFEATS and ) Magistrate Judge Komives

HENRY MISHKOFF, )

)

Defendants. )

DEFENDANT'S FIRST SET OF INTERROGATORIES
AND REQUESTS FOR PRODUCTION OF
DOCUMENTS AND THINGS TO PLAINTIFFS

Defendant Henry Mishkoff, pursuant to Rules 26, 33, and 34 of the Federal Rules of Civil Procedure, hereby propounds the following First Set of Interrogatories and Requests for Production of Documents and Things to Plaintiff, Taubman Company Limited Partnership, to be answered under oath within the time period required by law. The answers and requested documents shall be produced at the mailing address of Henry Mishkoff, 2661 Midway Road, #224-225, Carrollton, TX 75006.