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Discovery - Coggle Diagram
Discovery
Requests
Interrogatories (limited to 25 questions)
Requests for Production of Documents (no limit)
Requests for Admission (no limit)
Physical Exam
Mandatory Disclosures
Initial Disclosures (within 14 days after Planning Conference)
Persons with relevant info
Items in party's possession that support claim/defense
Computation of damages and supporting material
Relevant insurance policies
Disclosures of Expert Testimony (90 days before trial)
Written report with their opinions and bases for opinion, qualifications
Pretrial Disclosures (30 days before trial)
Testifying witnesses
Deposition testimony
Documents/Exhibits to be used at trial
Depositions (limited to 10)
Oral
Written
Motions
Protective Order (to oppose discovery)
Motion to Compel (discovery)
Electronically Stored Info (ESI) :desktop_computer::globe_with_meridians:
Parties must plan how ESI is preserved, searched, and produced
Production is proper if:
ESI is organized or labeled; and
ESI is produced in the form requested
No Duty to Produce ESI if:
Undue Burden; or
Cost
Deletion
Not sanctionable if inadvertent and done in good-faith