Discovery

Question 1

Mandatory disclosure

Answer 1

Within 14 days of the discovery conference, parties are required to automatically disclose:
(1) Any person with discoverable information;
(2) Documents supporting claims or defenses;
(3) Computation of damages; and
(4) Any relevant insurance to satisfy judgment.

Question 2

Expert witnesses

Answer 2

If an expert witness will testify, the identity of expert witnesses and their report must be disclosed at least 90 days before trial.

If the expert witness will not testify, their report is not discoverable.

Question 3

Pretrial disclosure

Answer 3

Testifying witnesses, deposition testimony to be used at trial, and documents and exhibits to be used at trial must be disclosed at least 30 days before trial.

Question 4

Scope of discovery

Answer 4

Discovery is limited to information that is (1) relevant to a party’s claim or defense and (2) proportional to the needs of the case.

Question 5

Deposition

Answer 5

Each party is limited to 10 depositions.

A subpoena duces tecum requires a nonparty deponent to bring specified
documents or things to the deposition

Question 6

Written interrogatory

Answer 6

A party is limited to 25 written interrogatories.

Written responses are due within 30 days of service.

Question 7

Mental/physical examination

Answer 7

A court can order a mental or physical examination if:
(1) a party’s mental or physical condition is in controversy;
(2) the motion is based on good cause; and
(3) the order provides notice.