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There are essentially six methods of discovery permissible under R. 4:10-1: (1) interrogatories, (2) document requests, (3) inspection of property and other things, (4) physical and mental examinations, (5) requests for admissions and (6) depositions. Each will be considered in turn.
However, before considering particular discovery devices, it is essential to understand the scope of discovery. Our discovery rules are intended to “eliminate, as far as possible, concealment and surprise in the trial of lawsuits to the end that judgments rest upon real merits of the causes and not upon the skill and maneuvering of counsel.” Abtrax Pharmaceuticals, Inc. v. Elkins-Sinn, Inc., 139 N.J. 499,512 (1995), quoting Olivero v. Porter Hayden Co. , 241 N.J. Super. 381, 387 (App. Div. 1990). Consistent with that view, R. 4:10-2 (a) permits discovery of all matters, not privileged, that are relevant “to the subject matter involved in the pending action.”
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