This chapter covers the various forms of written discovery available under the Kentucky Rules of Civil Procedure. These include interrogatories (CR 33), requests for production and inspection (CR 34), requests for admission (CR 36), and depositions upon written questions (CR 31). Attention is given throughout the chapter to the availability of sanctions for refusal to make discovery (CR 37).

Counsel should always consult local circuit court rules in addition to the Kentucky Rules of Civil Procedure. Although beyond the scope of this chapter, when practicing in federal court, counsel should consult the Joint Local Rules of Civil Practice for the United States District Courts for the Eastern and Western Districts of Kentucky (“Joint Local Rules”) in addition to the Federal Rules of Civil Procedure.