This is a federal default case - pyramid scheme and other fraud. Defendants are 3 individuals and 2 corporations. Def. have a mandated date to provide initial disclosures by end of Oct. Moreover, the settlement conference judge has a clause in standing orders that necessary discovery should be completed prior to settlement conference in Dec. I emailed the def. lawyer and asked to produce only a few documents including def. tax returns, income records, net worth and names of other victims. I am now working on an official request for documents. Can I limit it to my email request and make additional requests after the settlement conference if if it doesn't succeed? Can I send this request only to one defendant - the CEO of the company or the corporation itself? Are my requests valid?