As of the first of February, 1967, the entire field of discovery in Virginia has been radically changed from what it was before, and this has resulted in a great change in the method of modern litigation. On this date the substance of the federal rules of discovery was incorporated into the Virginia Rules of Court, Part Four.
This book will consider first those discovery devices which are most similar to pleadings and then those which were originally used for the presentation of evidence. Interrogatories were originally part of the pleadings in equity, and requests for admission are merely suggested answers to unasked interrogatories. Both of these devices, which are limited to use against other parties, and production of things by other parties are governed by the same rules and have the same scope. Production of things by non-party witnesses, depositions, and medical. examinations were originally means of gathering and presenting evidence.
William Hamilton Bryson, Discovery in Virginia (The Michie Co., 1978).