Section 649-103-6 - FORMAL DISCOVERY1. Defense counsel should, when needed, use formal discovery methods to obtain information. A. Defense counsel should know what information is needed to prepare for the case and understand the best methods of obtaining that information. (1) Defense counsel should become familiar with pretrial discovery requests and motions, and use whatever tools are available to obtain necessary information. Defense counsel should be aware of the limitations on the use of a subpoena to require the release of confidential information without a court order and should have subpoenas served in a timely manner to provide time for court involvement in the production of the documents sought.(2) Defense counsel should consider the following types of formal discovery: depositions, interrogatories (including expert interrogatories), requests for production of documents, requests for admissions, and motions for mental or physical examination of a party.(3) Defense counsel should file timely motions for discovery and renew these motions as needed to obtain the most recent records.(4) Defense counsel, consistent with the client's interests and goals and where appropriate, should take all necessary steps to preserve and protect the client's rights by opposing discovery requests of other parties.94- 649 C.M.R. ch. 103, § 6