Interrogatories, Request for Production of Documents: Discovery in Virginia Divorce

Interrogatories and Requests for Production of Documents are two of the most popular tools available in discovery. In fact, we use them in almost every single divorce case that gets to this point. Why? Because they’re relatively quick and easy, and we can usually get all the information we need from just these two documents.

Discovery is time-consuming and expensive, so we want to get the most bang for our buck. The way to do that, in most cases, is by using Interrogatories and Requests for Production of Documents. These tools have a wide scope, meaning that we can get a lot of different kinds of information, so there’s often not any reason to try anything else.


Interrogatories are, basically, a series of questions that we send to the other side. Usually, though, these questions are long and complex, so they look a lot more overwhelming and complicated than they actually are. For example:

“Describe each position of employment held by you, and include the name and address of your employer, the dates of your employment, your official title, if any, a description of all compensation that you received, including bonuses, and any benefits provided by the employment.”

It’s just one question, but it’s asking for a lot of different pieces of information. And this is just one that I found in a quick Google search!

In Virginia, you can ask 30 interrogatories.

Requests for Production of Documents

Usually, Requests for Production of Documents go hand-in-hand with interrogatories, because we use them to request the documents that back up the information provided in the interrogatories. If we’re curious about income, we’ll ask for pay stubs and income tax returns. If we’re asking about credit card debt, we won’t just take his word for it, we’ll ask for the statements to back it up. We can ask for information about any businesses he owns or retirement accounts, and then in the RFPs we can ask for the statements! Usually, we ask for statements dating back about 3 years.

In most cases, we can get enough information out of these two discovery tools to answer most of the questions we have, so discovery stops here. In some cases, though, things get a little more complicated and we have to go on to use requests for admissions.

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