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Discovery Process in Foreclosure: Complete Guide

Discovery is your most powerful tool in foreclosure litigation. Through interrogatories, requests for production, requests for admissions, and depositions, you can force the lender to prove its case — or expose fatal weaknesses. Learn discovery strategy for foreclosure cases.

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1. What Is Discovery?

Discovery is the pre-trial phase of litigation in which each party can obtain evidence from the opposing party. It is governed by court rules (Rules 26-37 of the Federal Rules, and equivalent state rules). Discovery serves two critical purposes in foreclosure defense: (1) it forces the lender to prove its case with actual evidence rather than mere allegations, and (2) it can uncover lender violations that create counterclaims and settlement leverage.

2. The Four Discovery Tools

Tool Description Best Use in Foreclosure
Interrogatories Written questions requiring sworn written answers Identify all entities in chain of title, note holders, servicers
Requests for Production Demand for documents and tangible evidence Original note, all assignments, servicing records, payment history
Requests for Admissions Statements the opposing party must admit or deny Force lender to admit it cannot produce original note or has no personal knowledge
Depositions Live, sworn testimony of witnesses Depose robo-signers, corporate representatives, servicer employees

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