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.

3. RULES: 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.

4. RULE 26(f) CONFERENCE / RULE 16(a): The Court requires Plaintiff to convene a conference pursuant to Fed.R.Civ.P.26(f) and follow the procedures as set forth in the Notice of Scheduling Conference.

5. DISCOVERY SCHEDULE: The length of time needed for discovery is to be considered seriously by the attorneys. Three to four months from the date of answer is considered sufficient in the ordinary case. Complex cases or cases involving discovery in foreign nations may take six to twelve months. The Court will honor a reasonable discovery schedule and timetable as suggested by the attorneys in their Rule 26(f) plan and implement it in a scheduling order.

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.