By Alan Hoffman (July 3, 2017, 1:55 PM EDT) -- Rule 11 of the Federal Rules of Civil Procedure, and state analogues, require that the factual contentions in pleadings "have evidentiary support or, if specifically identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery." As a result, plaintiffs' lawyers must do their homework before filing suit, learning as much as possible about the product in issue from open source materials and following up with focused written discovery. If an impending statute of limitations or other practical problem limits the opportunity for such research, plaintiffs often serve broad brush stroke discovery in an effort to identify documents, information and witnesses that might prove relevant and valuable in prosecuting their claims....