Rule 26(a)(1)(2) Initial and expert disclosures Form of request None necessary

Rule 30 & 45 Depositions

Rule 33 Interrogatories

Rules 34 & 45 Request for production of documents, ESI Request describing materials with reasonable particularity 34(b)(1) Subpoena nonparties under 45(a)(1) Documents, ESI, within the scope of 26(b) (also may be used for tangible things and entry on land)

Rule 35 Physical and mental exams Motion for court order requiring examination of a specified condition in issue and for good cause 35(a) Examination and report on specified physical or mental condition 35(b)(2)

Rule 36 Admissions

Notice of time and place; Subpoena to nonparties under 45(a)(1) Oral questions Oral testimony within the scope of 26(b)

Written questions relating to fact, contention, opinion, or application of law to fact 33(a)

Requests to admit statements of fact, opinion, application of law to fact 36(a)(1)(A)

Material to be produced (with a duty to supplement and correct 26(e))

Names of witnesses and documents party may use support of case Names of expert witnesses and reports

Answers separately and fully in writing under oath 33(b)(3)

Adnussions conclusively establishing matter in the statement 36(b)

Responses by producing party or person (also may move for protective order, with certification of effort to resolve without court order, 26(c))

Default numerical limit (all subject to criteria of scope in 26(b)(2)) Motions by party seeking discovery (with certification of effort to obtain disc. without court order) Sanctions (court must also impose sanction for improper certification of discovery request, respnse, objection, or disclosure 26(g))

Testify; object orally with testimony taken subject to objection object and direct not to answer in limited circs e.g., to protect privilege 30(c)(2) Motion to terminate 30(d)(3) 10 depositions; each one 7-hour day To compel disclosure 37(a)(3)(A) To compel an answer or designation 37(a)(3)(B); to terminate for bad faith 30(d)(3) For failure to attend 37(d); 30(g) For failure to obey a discovery order 37(b) For contempt 45(e)

Respond or object specifically 33(b) Answer may require research, time for other discovery 33(a)(2) Option to produce business records 33(d)

Object specifically or produce by category or as kept in the ordinary course of business 30(b)(2)

Submit to examination Person examined may request report; party seeking examination may then obtain other reports on same condition 35(b)

Admit, deny specifically, or state why not; May assert lack of knowledge only after reasonable inquiry 36(a)(4) & (5)

25 interrogatories, including discrete subparts To compel an answer or designation 37(a)(3)(B); For protective order 26(c) For failure to serve a response 37(d) For failure to obey a discovery order 37(b)

To compel inspection 37(a)(3)(B) For protective order 26(c)

Requesting order for examination 35(a) To compel production of report 35(b)(5) For failure to obey a discovery order 37(b)

To determine sufficiency of answer or objection 36(a)(6)

For failure to disclose 37(c)(1)

For failure to serve a response 37(d) For failure to obey a discovery order 37(b) For contempt 45(e)

For failure to admit 37(c)(2)