Does discovery have to proceed step-wise, or is it possible (or even routine) to combine the discovery process whenever possible? Here's a hypothetical example of what I mean:
I am suing an employer for discriminatory hiring practices against black candidates. Let us assume there is no question of law, but merely questions of facts. I might pursue the following discovery strategy:
- Request for admission: Do you discriminate against black candidates in your hiring processes? If not, then:
- Interrogatory: How many black applicants have you had for openings in the last year, and to how many of those did you extend offers of employment? If the answer is that you don't know, then:
- Request for Production: Produce all job applications you collected in the last year, and I'll figure it out.
The "step-wise* approach involves filing/serving each one of these on the opposing party, waiting for their response, and then (depending on the response) serving the next. Obviously in more complicated cases this could result in a lot of back and forth.
The "efficient" approach would be to serve all three as a single request, essentially as I wrote them here. Is this allowed? Common? Ill-advised?