DISCOVERY

(a) Presumptive Discovery Limits. Unless otherwise authorized by the provisions of the BCD scheduling order, each party may serve upon any other party no more than (1) 30 interrogatories, including all subparts; (2) 30 requests, including all subparts, for production of documents; (3) 20 requests, including all subparts, for admissions; and (4) 5 notices of deposition or subpoenas for deposition for persons other than experts. (b) Confidentiality Orders. A party by motion or with the agreement of all parties may submit to the court a proposed order governing the production and use of confidential documents and information in the pending action. The party or parties may (1) draft their own order or (2) utilize or customize a draft confidentiality order from an approved BCD form. The entry of a confidentiality order by the court does not limit the court’s power to make orders concerning the disclosure of documents produced in discovery, filed with the court, or presented at trial, including whether and its confidential under what circumstances the document will retain designation. 269