Answer to Question 1
The requesting party must give written notice. If the notice must state with particularity what matters will be asked about. It must provide the details of the kinds of questions that must be asked. If it is an organization, the notice must state that the organization has the duty to designate an officer, director, or managing agent to testify on its behalf.
Answer to Question 2
Parties should determine what documents are needed, their location, their value to the case, their format, and the costs of retrieving them.
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