There are Few Limitations on Post Judgment Discovery.
Frequently we are exposed to lawyers who do not know the rules change once a judgment has been entered. For instance, before trial you are limited as to the amount of discovery that can be conducted. For example, you are only allowed to send 25 interrogatories before trial. However, that limitation does not exist when you are collecting a judgment. So our ability to use the rules to gather the information we need to collect or judgment is virtually unlimited, so long as I request is reasonably calculated to lead to information about the assets of the debtor.