Civil Discovery

7.1 Time for discovery. (A) In non-Article 6 Probate Courts, in order for a party to utilize the court's compulsory process to compel discovery, any desired discovery procedures must first be commenced promptly, pursued diligently and completed without unnecessary delay, and within two (2) months after the filing of the answer, unless for cause shown the time has been extended or shortened by court order. (B) In Article 6 Probate Courts as defined in Rule 2.7, in order for a party to utilize the court's compulsory process to compel discovery, any desired discovery procedures must first be commenced promptly, pursued diligently and completed without unnecessary delay, and within six (6) months after the filing of the answer, objection, or other response. At any time, the court, in its discretion, may extend, reopen or shorten the time for discovery. 7.2 Filing requirements. (A) Depositions and other original discovery material shall not be filed with the court unless or until required by the provisions of OCGA § 9-11-29.1 (a) (1)-(5). (B) A party serving interrogatories, requests for production of documents, requests for admission, and answers or responses thereto upon counsel, a party or a non-party may file with the court a certificate indicating the pleading which was served, the date of service (or that the same has been delivered for service with the summons), and the persons served. 7.3 Depositions upon oral examination. Unless otherwise authorized by the court or stipulated by the parties, the duration of a deposition is limited to one (1) day of seven (7) hours. The court must allow additional time if needed for a fair examination of the deponent or if the deponent or another person or other circumstance impedes or delays the examination. 7.4 Failure to make discovery and motion to compel discovery. (A) Prior to filing a motion to compel discovery, counsel for the moving party shall confer with counsel for the opposing party in a good faith effort to resolve the matters involved. At the time of filing the motion, counsel shall also file a statement certifying that such conference has occurred, and that the effort to resolve by agreement the issues raised failed. If some of the issues have been resolved by agreement, the statement shall specify the issues remaining unresolved. (B) Motions to compel discovery in accordance with OCGA § 9-11-37 shall: 1. Quote verbatim or attach a copy as an exhibit of each interrogatory, request for admission, or request for production to which objection is taken; 2. Include the specific objection or response said to be insufficient; 3. Include the grounds assigned for the objection (if not apparent from the objection); and 19 4. Include the reasons assigned as supporting the motion. Such objections and grounds shall be addressed to the specific interrogatory, request for admission, or request for production and may not be made generally.