I represent the Plaintiffs in such a case, but although I have experience drafting Discovery requests, I don't have much experience in drafting Defamation/Libel Discovery requests. I would sincerely appreciate any help.
Jack Puskar, Attorney at Law
jkpush at yahoo.com
Before I respond to your inquiry, I must state that we have not spoken, I have not reviewed the relevant documents and facts, and I do not represent you. Therefore, my discussion below is not a legal opinion, but is informational only. Finally, my discussion applies only to issues to which Pennsylvania, New Jersey or Federal law apply, unless otherwise specified.
That being said, defamation issues are so fact-specific that I don't use form discovery requests for them. Look at your facts and look at the elements of the claims and the jury instructions you are going to use, and you can create your own from those.
I'm also not a big fan of interrogatories these days; they tend to be fairly useless - I target them to the issues I have to address in rogs, and then use depositions (and sometimes requests for admission) to get what I need.
The biggest headache you'll have is the requests for production and/or inspection. If this is a case involving digital media/internet/email, then your requests for production is the more important discovery tool you will use. Metadata and original file access are issues to which you should pay special attention.
I'm happy to discuss with you if you like; you can reach me at the below number.
/Christopher E. Ezold/
The Ezold Law Firm, P.C.
One Belmont Avenue,
Bala Cynwyd, PA 19004