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1.     Commencement: Counsel may commence discovery immediately after receipt of the Answer to the Complaint. 

2.     Discovery limitations: Parties are bound by Fed.R.Civ.P.30(d)(2) concerning depositions and Fed.R.Civ.P.33(a) limiting the number of interrogatories. 

3.     Discovery schedule: Three to four months for case discovery from the date of answer is the average length of the time for most cases. Complex cases or cases involving discovery in foreign nations may take six to twelve months. The Court will honor a reasonable discovery schedule suggested by the attorneys in a Rule 26(f) plan. 

4.     Protective orders:  If a protective order which permits filing materials under seal is granted, either upon motion or stipulation of the parties, the Court requires that the order contain language concerning the manner in which protected material is to be filed under seal and the manner in which the material is to be disposed of. See E.D. Mich. LR 5.3 and 5.4.

     The following language will satisfy the requirement regarding how the material is filed under seal:

Filing Protected Documents. "Protected" documents are to be sealed in a 9 x 12 inch envelope. The envelope shall have the following information printed on its face: (1) the name of the court, (2) the title of the case, (3) the case number, (4) the name of the document, (5) the attorney's name, address and the party he or she represents and (6) the following language: "Confidential Material Pursuant to Protective Order." A copy of the Protective Order shall also be attached to the outside of the envelope. 

     The following language will satisfy the requirement regarding the disposition of material filed under seal at the conclusion of the case:

Procedure Upon Termination of This Action. Sixty days after the termination of this action by order or judgment, or by an appellate mandate if appealed, the material submitted under seal pursuant to this protective order will be unsealed and placed in the public case file, unless counsel present a proposed order to arrange for the return of the materials from the Clerk's Office to the parties responsible for their submission, at the responsible party’s expense. An order for the return of protected documents to the parties or attorneys who submitted them shall require counsel to maintain one archival copy of depositions exhibits, transcripts, Court exhibits and transcripts, and documents and information included in submissions to the Court.

5.     Witness lists: A witness list must be filed in every case at least two months before the final pretrial conference.  The parties are to name witnesses they reasonably and in good faith expect will be called at trial.

6.     Allowable time: Sufficient time must be given to answer interrogatories and complete depositions BY THE DISCOVERY CUTOFF DATE.

7.     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.

8.    Additional dates: Counsel may, but need not, recommend deadlines WITHIN THE DISCOVERY PERIOD for expert reports and depositions. However, unless otherwise ordered, the plaintiff must submit an expert report eight weeks before the close of discovery, and the expert must be available for deposition within two weeks thereafter. The defendant must submit an expert report no later than four weeks before the discovery cutoff date, and, likewise, the expert must be available for deposition within two weeks thereafter.

9.     Magistrate Judge: Discovery motions are routinely referred to the magistrate judge. Once a motion has been referred, all communication regarding that motion should be directed to the magistrate judge’s chambers.

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