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It is the intent of this rule that a party must produce all responsive documents, objects or tangible things in its possession, and fully disclose the partys knowledge of the existence and location of responsive documents, objects or tangible things not in its possession so as to enable the requesting party to obtain
A party can only send 30 interrogatories. However, this number can be increased if the other party agrees or the court allows more. If there is more than one other party in the case, the requesting party must give copies to all other parties. A party who receives interrogatories has 28 days to answer or object.
All dates set for the disclosure of witnesses, including rebuttal witnesses, and the completion of discovery shall be chosen to ensure that discovery will be completed not later than 60 days before the date on which the trial court reasonably anticipates that trial will commence, unless otherwise agreed by the parties.
During discovery, both sides exchange evidence to learn what the other side intends to use in court. Discovery refers to tangible objectsor anything that you can physically touch. For example, this may include a gun with fingerprints on it or a stack of physical documents.
How Does Discovery Work? There are four main types of discovery requests: (1) depositions; (2) interrogatories; (3) requests for admissions; and (4) requests for the production of documents. Depositions are formal witness interviews.
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If the deposition was or would be admissible as substantive evidence at trial in the other iurisdiction, the deposition is deemed an evidence deposition. If not, the deposition is deemed a discovery deposition.
A party responding to requests for production must furnish an affidavit stating whether the production is complete in ance with the request. Copies of identifications, objections and affidavits of completeness shall be served on all parties entitled to notice.

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