It's pretty much impossible to tell someone how to litigate, even if we did know something about your lawsuit, which we don't.
Generally parties can't offer evidence at trial that they haven't produced in discovery, but there are many exceptions to this rule, such as for use to impeach a witness.
You do seem suspicious of the other parties' tendency to falsify documents, which might make appropriate propounding Requests for Admission as to genuineness of documents and facts.
You're of course best off consulting with a lawyer to help you.
Avvo doesn't pay us for these responses, and I'm not your lawyer just because I answer this question or respond to any follow-up comments. If you want to hire me, please contact me. Otherwise, please don't expect a further response. We need an actual written agreement to form an attorney-client relationship. I'm only licensed in CA and you shouldn't rely on this answer, since each state has different laws, each situation is fact specific, and it's impossible to evaluate a legal problem without a comprehensive consultation and review of all the facts and documents at issue.
Discovery is a vital part of litigation, and has to be harnessed to the overall goal of the case. You want to try to get everything you can that will help you, and find out anything that might hurt your case. The entire process is set up to achieve substantive justice for the parties and for society. There are many pitfalls and challenges. These are all questions that you need to ask your lawyer. If you are doing it yourself, you need to think whether that is wise. I don't feel qualified to take on Kobe Bryant in a basketball game, especially if my money is one the line.
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First of all, it sounds like you are in federal court, not state court.
Keep in mind that most litigators practice in state court, and would not be sufficiently familiar with the Federal Rules of Civil Procedure to help you. With that in mind, it is even more important for you to consult with a litigation attorney who knows federal court practice and procedure.
No one on Avvo can really teach you how to propound effective discovery, nor can anyone predict what the other side might do to defeat you at trial. Please consult with an attorney. You do not have much time left.
Frank W. Chen is licensed to practice law in the State of California. The information presented here is general in nature and is not intended, nor should be construed, as legal advice. This posting does not create any attorney-client relationship with the author. For specific advice about your particular situation, consult your own attorney.