Discovery

Unless otherwise provided in the case management order, each side may take no more than two depositions limited to three hours each. Each side may propound requests for production, interrogatories, and requests for admission, each not exceeding 20 in number including all discrete subparts. The court may set additional limits or provide for further discovery in the initial case management order, upon a showing of good cause and proportionality. No other discovery will be permitted absent further court order based on a showing of good cause and proportionality. Discovery shall be limited to matters that would enable a party to prove or disprove a claim or defense or to impeach a witness and shall comport with the factors of proportionality. History: Amended October 15, 2014, effective January 5, 2015.