ga-discovery

name	ga-discovery
description	This skill should be used when drafting, responding to, or compelling discovery in a Georgia civil case. Triggers include "Georgia interrogatories", "interrogatories under O.C.G.A. § 9-11-33", "requests for production Georgia", "requests for admission deemed admitted", "RFA Georgia", "Georgia deposition", "discovery period", "discovery deadline Georgia", "motion to compel Georgia", "protective order Georgia", "subpoena Georgia". Covers the Georgia Civil Practice Act discovery framework (O.C.G.A. §§ 9-11-26 to 9-11-37): the scope of discovery, the 50-interrogatory cap, requests for production, the requests-for-admission deemed-admitted trap, depositions, the 30-day (45-day if served with the summons) response window, the six-month USCR 5 discovery period, protective orders, supplementation, motions to compel with expenses, and subpoenas.
version	0.1.0

Georgia Discovery

NOT LEGAL ADVICE. This skill helps draft and respond to discovery. Verify against the current Georgia Civil Practice Act, the Uniform Court Rules, and the assigned judge's standing orders before serving or filing.

Use this skill alongside ga-statewide-format, ga-law-references, and (where applicable) ga-first-30-days. Georgia civil discovery derives from the Georgia Civil Practice Act, O.C.G.A. §§ 9-11-26 through 9-11-37, with the discovery period set by the Uniform Court Rules.

Snapshot — Georgia discovery clock

Trigger	Deadline / event	Authority
Discovery period	6 months from the filing of the answer	USCR 5
Written-discovery responses (served after the answer)	30 days after service	O.C.G.A. §§ 9-11-33, 9-11-34, 9-11-36
Written-discovery responses (served with the summons)	45 days after service	O.C.G.A. §§ 9-11-33, 9-11-34, 9-11-36
Extension / shortening of the discovery period	by stipulation or court order	USCR 5

Frame day counts and the period start with cites; defer the exact calendar arithmetic (weekend / § 1-4-1 holiday roll-forward under O.C.G.A. § 1-3-1(d)(3)) to ga-deadlines / case-calendar.py.

Scope of discovery — O.C.G.A. § 9-11-26(b)

Parties may obtain discovery of any matter, not privileged, that is relevant to the subject matter of the action (O.C.G.A. § 9-11-26(b)). It need not be admissible if it appears reasonably calculated to lead to admissible evidence. The scope governs every device below.

Interrogatories — O.C.G.A. § 9-11-33

Georgia DOES allow written interrogatories.

• Cap: 50 interrogatories, including subparts (O.C.G.A. § 9-11-33). Count each discrete subpart toward the limit; exceeding it requires leave of court.
• Service: any time after commencement (subject to the response-window rules above).
• Response due: 30 days after service — 45 days if served together with the summons (O.C.G.A. § 9-11-33).
• Form: each interrogatory answered separately and fully, under oath, with any objection stated in lieu of an answer.

INTERROGATORIES

Pursuant to O.C.G.A. § 9-11-33, [Defendant] requests that [Plaintiff]
answer the following Interrogatories separately and fully, in writing
and under oath, within the time allowed by law.

INTERROGATORY NO. 1: State the name, address, and telephone number of
each person with knowledge of the facts alleged in the Complaint.

ANSWER:
[Response]

INTERROGATORY NO. 2: [...]

Requests for Production — O.C.G.A. § 9-11-34

• Reach documents, electronically stored information, and tangible things within a party's possession, custody, or control, and entry on land for inspection (O.C.G.A. § 9-11-34).
• Response due: 30 days after service (45 days if served with the summons).
• Each request must be responded to specifically; production or a stated objection per item.

Requests for Admission — O.C.G.A. § 9-11-36

⚠ The deemed-admitted trap. Under O.C.G.A. § 9-11-36, a matter is admitted unless the party served answers or objects within the response period (30 days, or 45 if served with the summons). Silence or a late response can conclusively establish the requested facts for the case. This is the single most dangerous discovery device for an unrepresented party — calendar RFA deadlines first.

• Each request must be admitted, denied, or met with a statement of why the party cannot truthfully admit or deny.
• A party may move to withdraw or amend an admission under the standard in O.C.G.A. § 9-11-36(b), but relief is not automatic.

Depositions — O.C.G.A. §§ 9-11-30, 9-11-31

• Oral depositions under O.C.G.A. § 9-11-30; depositions on written questions under O.C.G.A. § 9-11-31.
• Notice must state the time and place; a non-party deponent is compelled by subpoena (see below).
• An organization may be deposed through a designated representative on described matters (O.C.G.A. § 9-11-30(b)(6)).

Protective orders — O.C.G.A. § 9-11-26(c)

On motion and for good cause, the court may enter a protective order to shield a party or person from annoyance, embarrassment, oppression, or undue burden or expense — including orders that discovery not be had, be had on specified terms, or be limited in scope (O.C.G.A. § 9-11-26(c)). A motion for a protective order should document a good-faith effort to resolve the dispute first.

Supplementation — O.C.G.A. § 9-11-26(e)

A party is under a duty to supplement prior responses in the circumstances set out in O.C.G.A. § 9-11-26(e) — including newly identified witnesses and corrections of responses later learned to be incorrect.

Motion to compel and expenses — O.C.G.A. § 9-11-37

If a party fails to answer, answers evasively or incompletely, or asserts unfounded objections, the requesting party may move to compel under O.C.G.A. § 9-11-37(a). The motion should:

1. Identify each deficient response (which interrogatory / request for production / request for admission and why it is inadequate).
2. Attach the requests and the responses as exhibits.
3. Document the effort to confer in good faith to obtain the discovery without court action.
4. Request specific relief — an order compelling responses by a date certain and an award of the reasonable expenses, including attorney's fees, that O.C.G.A. § 9-11-37(a)(4) authorizes against the losing party absent substantial justification.

Stronger sanctions for disobeying a discovery order — including striking pleadings, dismissal, or default — are available under O.C.G.A. § 9-11-37(b).

Subpoenas — O.C.G.A. § 24-13-23 and § 9-11-45

• Subpoenas to non-parties for testimony or documents issue under the Evidence Code, O.C.G.A. § 24-13-23, with the civil-discovery subpoena mechanics of O.C.G.A. § 9-11-45.
• A subpoena may command attendance at a deposition or trial and may require production of documents and tangible things.
• Serve a copy of any documents-only subpoena consistent with the notice requirements so opposing parties can object.

Discovery in Magistrate Court

Magistrate Court ($15,000 civil cap) runs a relaxed procedure under O.C.G.A. §§ 15-10-40 to 15-10-53 in which the formal CPA discovery devices generally do not apply; discovery there is limited and court-directed. The full §§ 9-11-26 to 9-11-37 framework above is the State / Superior Court regime. See ga-magistrate. Note that post-judgment discovery in aid of execution remains available under O.C.G.A. § 9-11-69 (see ga-post-judgment).

Composition

• For format baseline: ga-statewide-format
• For deadline arithmetic (period start, response windows): ga-deadlines
• For drafting the motion to compel: ga-draft-motion
• For the supporting affidavit / declaration: ga-draft-declaration
• For the usual debt forum and the relaxed Magistrate procedure: ga-state-court, ga-magistrate
• For consumer-debt RFP / RFA / interrogatory banks and the business-records (O.C.G.A. § 24-8-803(6)) foundation fight: ga-consumer-debt
• For verifying citations before serving or filing: ga-fact-check

References

• references/interrogatory-templates.md — Georgia interrogatory sets (50-cap aware) and answer/objection forms
• references/rfp-rfa-templates.md — requests for production and requests for admission, with deemed-admitted warnings
• references/motion-to-compel.md — § 9-11-37 motion-to-compel scaffold with the expenses request