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Filed

D served

D appears

26f conference (parties) at least 21 days before 16b conference

disclosures

scheduling order (16b conf) no later than 120 days after service or 90 days after D appears

What is Discoverable?

Privileged Relevant

Unreas C or D

Attorney Work Product

Experts

Substantive expert: testifying

Fact witnesses

Substantive expert: consulting (no report)

THE FILTERS

Disputes

Filter: no atty

Lawsuits

filter: 12b6

Well-pled

filter: 56

Lawsuits w/evidence

filter: trial

Complaint & Service Rules 8, 4

Parties' Conference & Discovery Plan

Initial Disclosures

Scheduling Order Rule 16(b)

Party-Initiated Discovery Rules 26-35

Exchange of Experts' Reports & Depositions Rule 26(a)(2), (b)(4)

Pretrial Disclosures

Final Pretrial Order-Superseding the Pleadings

Rule 26(f)

Rule 26(a)

Rule 26(a)(3)

Rule 16(e)

Stages of Discovery

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