Which item is NOT typically a tool used in the discovery process?

• A. Interrogatories
• B. Depositions
• C. Requests for Production
• D. Motions for Summary Judgment

Answer: (D)

Discovery tools are the methods used to uncover facts and obtain evidence from the other side or from witnesses. Interrogatories are written questions you can send to the other side to get factual details. Depositions involve sworn, oral testimony taken under oath, with the opportunity for cross-examination. Requests for Production seek specific documents or other tangible items to be turned over.

A Motion for Summary Judgment is not a discovery tool. It’s a post-discovery or pre-trial step asking the court to rule on the case because there’s no genuine dispute about any material fact and the moving party is entitled to judgment as a matter of law. It relies on evidence already gathered, not on new fact-finding. While discovery provides the materials that can be used to support or oppose a summary judgment motion, the motion itself is about resolving the case on legal standards rather than continuing fact discovery.