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Drafts and responds to discovery in Oregon civil cases: RFPs, depositions, RFAs, meet-and-confer, and motion-to-compel with ORCP 46 fee-shifting. Covers Oregon's no-interrogatories rule.
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This skill covers the **matter-neutral procedural framework** for
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This skill covers the matter-neutral procedural framework for
discovery in Oregon civil practice. The full ORCP text lives in
or-law-references/references/civil-rules.md. For subject-
matter-specific request banks (e.g., debt-buyer chain-of-title
RFPs), compose with the relevant subject-matter skill.
NOT LEGAL ADVICE. Verify each rule and the local SLR before drafting.
The single most important fact about Oregon civil discovery: Oregon does NOT have written interrogatories under the ORCP as a matter of right.
Available discovery tools:
Why no interrogatories? Oregon's Council on Court Procedures historically rejected the FRCP 33 model on the theory that written interrogatories generate boilerplate disputes without producing meaningful information; depositions and RFPs are sufficient.
Practical implications:
The scope test, identical to FRCP 26(b)(1):
Beyond the scope test, ORCP 36 sets:
The workhorse rule in Oregon discovery.
A well-drafted RFP is:
Example (well-drafted):
Request for Production No. 3: All documents constituting, referencing, or summarizing the original cardholder agreement between Defendant John Doe and Bank of America for account number ending in XXXX, including signature pages, incorporated terms and conditions, and any electronic acceptance records.
Example (poorly drafted):
Request for Production No. 3: All documents related to the account.
| Objection | Response |
|---|---|
| Overbroad | Narrow the temporal or party scope; or stand on the request and let the court rule |
| Burdensome | Quantify the actual burden; ORCP 36 proportionality is a balancing test |
| Privileged | Request a privilege log per ORCP 36 B(2); the bare assertion is insufficient |
| Relevance | Cite the specific claim or defense the request relates to |
| Not in possession, custody, or control | Verify; "possession" includes documents the party can access by ordinary means |
| Trade secret | Propose a protective order under ORCP 36 C |
| Premature | Many objections labeled "premature" are actually relevance — push back |
Pro se litigants can take depositions, but the mechanics (reservation of court reporter, subpoena issuance, recording agreements) are complex. Many pro se litigants substitute the deposition by written questions under ORCP 40 for simple factual depositions — slower but procedurally simpler.
RFAs are powerful in Oregon because:
Each RFA should be a single, simple fact — compound RFAs get partial denials that are hard to use. Example:
Request for Admission No. 5: Admit that Plaintiff is a Delaware limited liability company.
NOT:
Request for Admission No. 5: Admit that Plaintiff is a Delaware LLC organized in 2017 with its principal place of business in New Jersey and that it filed a Foreign LLC Registration in Oregon on April 1, 2024.
The compound form invites the response "Admitted in part, denied in part" with no usable narrowing of issues.
Mandatory under ORCP 46 A — and under most local SLRs (e.g., Multnomah SLR 5.045 / Washington Co SLR 5.046).
The meet-and-confer:
To: [opposing counsel]
Subject: Meet and Confer — Discovery Dispute, Case No. 25CV12345
Counsel:
I am writing to meet and confer under ORCP 46 A (and Multnomah
SLR 5.045) regarding the discovery responses you served on
[date]. Specifically:
1. RFP No. 3 (cardholder agreement) — your objection on
grounds of burden. We disagree because [reasons]. We
request that you supplement the response within 14 days,
by [date]. If you cannot, please let us know whether the
burden can be addressed by [proposed alternative —
sampling, time-limited subset, etc.].
2. RFP No. 5 (assignment schedule) — your objection on
grounds of relevance. We disagree because [reasons]. We
request supplementation within 14 days.
3. RFP No. 6 (account history) — your objection on grounds
of privilege. The bare assertion is insufficient under
ORCP 36 B(2). Please provide a privilege log identifying
each document withheld within 14 days.
If we cannot resolve these by [date], we will move to compel
under ORCP 46 A.
I am available by phone at [number] to discuss before [date].
Please let me know a good time.
Best,
[Name][, pro se]
The follow-up email confirming the call (and stating the opposing party's position) is what the meet-and-confer certification recites.
Mandatory if the motion is granted, unless the opposing party's failure was "substantially justified" or other circumstances make an award unjust.
The fee award is in addition to whatever sanctions (ORCP 46 B) the court may impose. Track time spent on the motion — a fee petition under ORCP 68 follows.
In Multnomah / Washington County (and many other counties):
CERTIFICATION OF MEET AND CONFER
(Multnomah SLR 5.045 / ORCP 46 A)
Pursuant to Multnomah SLR 5.045 and ORCP 46 A, counsel for
Defendant certifies that:
1. On [date 1], Defendant served First Requests for Production
Nos. 1–6 on Plaintiff.
2. On [date 2], Plaintiff served Responses, objecting on
grounds of [grounds] without producing responsive documents.
3. On [date 3], Defendant sent a meet-and-confer letter to
Plaintiff (Exhibit 3) identifying the specific objections,
explaining Defendant's position, and requesting
supplementation within 14 days.
4. On [date 4], Plaintiff responded (Exhibit 4), declining to
supplement.
5. The parties have been unable to resolve the discovery
dispute and are at impasse.
Defendant therefore respectfully requests an order compelling
production under ORCP 46 A.
A party from whom discovery is sought may move for a protective order to:
The standard: good cause. The court balances the burden against the need.
If the case is in ORS 36.400 mandatory arbitration, discovery is limited to what the arbitrator's rules permit. Some arbitrators allow interrogatories by stipulation; most rely on ORCP 43 RFPs and short depositions.
If discovery disputes arise in arbitration, motion to the arbitrator, not the circuit judge. The circuit judge hears disputes about the arbitration process (e.g., arbitrator disqualification), not substantive discovery.
This skill is matter-neutral. For pre-built request banks:
or-consumer-debt/ references/rfp-debt-buyer.md and rfa-debt-buyer.mdor-landlord- tenant/references/or-personal- injury/references/references/meet-and-confer.md — full meet-and-confer
protocol with sample emails and call-log templatesreferences/objection-responses.md — drafting responses to
RFPs, including objection libraries