I have a mental checklist that I run through each time I serve an initial set of written discovery to a personal injury plaintiff. This may seem mundane or obvious to the seasoned trial lawyer, but you likely did not learn about the practicalities of discovery in law school. If your training was anything like mine, you “learned” how to prepare discovery by copying discovery requests from a similar case. There is nothing wrong with copying discovery requests, and this should be done where it makes sense, but this resulted in me never taking the time, until recently, to sit back and think of what the purpose of discovery is and how it should be used effectively. As my mental checklist has developed, my written discovery has become more effective, less objectionable, and tailored to the issues and needs of each case.