Scope of Discovery

The scope of discovery is generally wide open.  Rule 26(b) of the Mississippi Rules of Civil Procedure provides that "Parties may obtain discovery regarding any matter, not privileged, which is relevant to the issues raised by the claims or defenses of any party."  In family law, this pretty much puts everything on the table including medical history and confidential employer information which may be relevant to earning capacity.  On the personal injury side, look at issues of net worth for punitive damages calculations and prior claims against a Defendant as a pattern of conduct.   All of this is permitted from my reading of the rules and has generally been allowed in a number of cases I have been involved in after a lot of unnecessary objections by opposing counsel and a trip to visit the judge.  This is where some long hard thinking on what you are seeking to prove can be useful and lead to some admissible evidence that you might not normally think about.