There is little commentary one need make on discovery in slips, trips, and falls. Attached, you will find examples of an initial claim letter requesting fundamental discovery, intended to be sent to a landowner. You’ll also find sets of questions for various types of cases.
You’ll note I say “questions,” not interrogatories or deposition questions. Everyone has a preference, and mine is to talk to people rather than send interrogatories. I like requests for production of documents and not interrogatories. Interrogatories get lawyered, deposition testimony does not. So look at the questions attached, and think about the best implementation in your case.
After all, when you file suit in a slip, trip, or fall, you ordinarily have limited information. Discovery through discovery is key.