A summary of the expert’s opinions and the basis therefore and a brief description of the expert’s qualifications. A brief description of the witness’ relevant knowledge. Disclosure of witnesses under this rule shall include the following information: Each party shall, no later than the date for disclosure designated in the Case Schedule, disclose all persons whose knowledge did not appear relevant until the primary witnesses were disclosed and whom the party reserves the option to call as witnesses at trial. Each party shall, no later than the date for disclosure designated in the Case Schedule, disclose all persons with relevant factual or expert knowledge whom the party reserves the option to call as witnesses at trial. This rule does not modify a party’s responsibility to seasonably supplement responses to discovery requests or otherwise to comply with discovery before the deadlines set by this rule. If the case is not assigned to a judge, the motion shall be made to the Respective Chief Judge. Motions for protective order, even if agreed, shall be presented to the assigned judge and not to the ex parte department. A motion to seal must be made separately pursuant to LGR 15 and cannot be submitted as part of a protective order. These discovery limitations do not apply to family law proceedings as defined by LFLR 1, supplemental proceedings undertaken pursuant to LCR 69(b) or other post-judgment proceedings. Fax or e-mail notification is permitted, provided (1) the parties have previously agreed to receive pleadings in this manner or (2) the objecting party also provides telephonic notification. Notice shall be in writing and shall be provided in the manner that is most likely to provide actual notice of the objection. This notification shall occur as soon as possible and, absent extraordinary circumstances, shall not be later than 24 hours before the scheduled deposition. (C) Absent a court order or stipulation altering the scope of discovery, a party served with a notice of deposition in violation of this rule shall inform all parties to the case that he or she will not be attending the deposition. The party shall indicate in the answer section of the Interrogatories or Requests for Admission that the party is refusing to respond to the remaining questions because they exceed the discovery limits. No motion for protective order is required. (B) Absent a court order or stipulation altering the scope of discovery, the party served with interrogatories or requests for admission in violation of this rule shall be required to respond only to those requests, in numerical order, that comply with LCR 26(b). (A) Unless authorized by order of court or written stipulation, a party may not serve requests for admission or interrogatories or note depositions except as authorized by this rule. (6) Discovery requests in violation of rule. A certificate of compliance as required by LCR 37(f) shall be filed with the motion. The proposed order shall include details of what additional discovery is required. If the parties do not agree that discovery in excess of that provided by these rules is necessary, a party may file a motion to submit additional discovery pursuant to LCR 7(b). Such plan need not be submitted to the court for approval. The parties may establish a written timetable for discovery and develop a discovery plan that will facilitate the economical and efficient resolution of the case. Nothing in this rule precludes the parties from engaging in the informal exchange of information in lieu of formal discovery. These limitations may be increased or decreased by written stipulation of the parties based on the scope of the legal and factual issues presented. A party may serve no more than 25 requests for admission upon any other party in addition to requests for admission propounded to authenticate documents. A party may take no more than 10 depositions, with each deposition limited to one day of seven hours provided, that each party may conduct one deposition that shall be limited to two days and seven hours per day. In cases where a party has not propounded pattern interrogatories pursuant to LCR 33, a party may serve no more than 40 interrogatories, including all discrete subparts. (B) Cases Without Court-Approved Pattern Interrogatories. In cases where a party has propounded pattern interrogatories pursuant to LCR 33, a party may serve no more than 15 interrogatories, including all discrete subparts, in addition to the pattern interrogatories. (A) Cases With Court-Approved Pattern Interrogatories. (1) Scope.This rule shall apply to all cases governed by a Case Schedule pursuant to LCR 4.
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