Respond & protect
The lawful response states and protection levers Washington discovery provides — shown with their rules; choosing among them for YOUR requests is legal judgment.
The response states, honestly
Answer separately and fully under oath (CR 33); respond per item or category within 30 days — a defendant's first window runs 40 days from the summons (CR 34); and NEVER sit on requests for admission — the matter is ADMITTED unless answered within 30 days (CR 36).
CR 33 · CR 34 · CR 36
Objections with reasons
Objection reasons are stated in lieu of an answer — and the CR 26(g) signature certifies the objection is grounded, not tactical. Boilerplate is a certification problem, not a style choice.
CR 33; CR 26(g)
The protective order
Good cause against annoyance, embarrassment, oppression, or undue burden or expense — the lever for scope fights, sequencing, confidentiality terms, and who may be present.
CR 26(c)
Work product + experts
Trial-preparation materials carry the substantial-need/undue-hardship shield with mental impressions protected; expert discovery runs on CR 26(b)'s own expert provisions.
CR 26(b)
THE CONFERENCE COMES FIRST
The court will not entertain ANY motion or objection under rules 26 through 37 unless counsel have conferred — arrange the conference, hold it, certify it. It is the doorway to every compel and every protective order.
CR 26(i)
The expenses ladder cuts both ways
A granted compel motion carries the movant's reasonable expenses unless opposition was substantially justified — and a DENIED motion carries the responder's. Positions get priced.
CR 37
The whole device board lives on the discovery plan →
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