This early meeting with your opponent is designed to discuss pleadings, the possibility of settlement and to develop a proposed discovery schedule.
What is the Discovery Planning Meeting (per FRCP 26(f))
100
This discovery tool involves submitting written questions that your opposing party is required to answer in writing under oath.
What are Interrogatories (FRCP 33)
100
This expensive discovery tool permits the interactive questioning, under oath, of parties, witnesses or experts.
What are Depositions (FRCP 30)
100
This definition of relevance under FRCP 26(b)(1) guides the permissible scope of discovery in civil cases.
What is: Any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case....
(will also accept)
What is: Information ... need not be admissible in evidence to be discoverable.
200
Recent amendments to Rule 26 address discovery and limitations of discovery on this type of technological material.
What is Electronically Stored Information
200
This discovery tool requires a party to turn over or make available for inspection documents or tangible things.
What are Requests for Production (FRCP 34)
200
This notice under Rule 30(b)(6) permits deposition of someone without naming that individual person in the notice.
What is notice to depose a corporation, partnership, association, governmental agency or other entity.
300
This type of disclosure is required of each party and does not require a formal request to precede them
What is Initial Disclosures Under FRCP 26(a)(1)
300
This discovery tool, governed by FRCP 36, can require parties to admit or deny factual assertions and admit or deny the genuineness of documents.
What are Requests for Admission (of Facts and Genuineness of Documents).
300
This rule of civil procedure provides for sanctions if a party fails to make disclosures or cooperate in discovery.
What is FRCP 37.
400
Parties are required to submit this document to the court within 14 days of conferring with their opponent at the Discovery Planning Meeting.
What is the Report of the Parties’ Planning Meeting (per FRCP 26(f))
400
This is the person who is required to answer Interrogatories.
Who is the party to whom they are directed.
400
Before filing a motion to compel discovery, an attorney must do this with her opponent first
What is confer or attempt to confer in good faith. (FRCP 37)
500
These are two reasons to object to an opponent's discovery request.
What is Privileged Material and Work Product
Will also accept: Cumulative or Duplicative; Unduly Burdensome; Irrelevant; Annoyning; Embarrassing; Oppressive; or Overly Broad.