1. EXCLUSIONS: These discovery rules do not apply to the following types of actions: ERISA or other action for review on an administrative record; petition for habeas corpus; prisoner civil case where prisoner is unrepresented; an action to enforce or quash an administrative summons or subpoena; an action by the United States to recover benefit payments or student loans; and, an action to enforce an arbitration award.
2. COMMENCEMENT: Counsel should commence discovery immediately after receipt of the Answer to Complaint.
6. ADDITIONAL DATES: Counsel may, but need not, recommend deadlines WITHIN THE DISCOVERY PERIOD for expert reports, depositions, and other pertinent matter.7. WITNESS LISTS: A witness list must be filed in every case by the date set forth in the scheduling order. The parties are to name witnesses they reasonably and in good faith expect will be called at trial. Laundry lists are not allowed.
8. ALLOWABLE TIME: Sufficient time must be given to answer interrogatories and complete depositions BY THE DISCOVERY CUTOFF DATE.
9. EXTENSIONS OF DISCOVERY: Parties may stipulate to a short extension of discovery by presenting an order to the Court. If there is no stipulation, or the Court denies the stipulated order, a request for extension for good cause shown may be made by motion.
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