Discovery: What does the adversary have that I want?

What do I have that the adversary wants?

Can I legally hide any of it?
 Complaint & Service
Rules 8,4 .

90 day period,
Parties' Conference and Discovery Plan: Rule 26(F) maximum – or
--> Plan MUST be submitted to --> Initial disclosures MUST be Minimum
60 if D
the court within in 14 days made within 14 days or within 30 period of
days after being served or joined: appears
21 days
Rule 26(a) between

Scheduling Order: Rule 16(b)

AFTER receiving 26(f) report OR after CAN be modified for good cause,
scheduling conference with judge's consent

1. What are all the diff types of conferences that can occur before trial

2. What is the difference between a 16 conference and a 26(f) conference?

3. What is a scheduling order and is it may or must?

Yes, it is a must

4. Can there be formal discovery before a 26(f) conference?

No, but there is exception in 34

Complaint . . . 90 days if defendant has been served or 60 if D appeared 16(b)(2)  judge must issue a
scheduling order 16(b)(1) [contents of the order required/permitted 16(B)(3)] [judge can modify the order
16(b)(4)]  branches off into following 2
parties conference 26(f) 16(b)(1)(A) OR
scheduling conference (meeting w the judge) 16(b)(1)(B)

Parties conference 26(f)

- at least 21 days before a scheduling conference or order 26(f)(1)
- 14 days to file a discovery plan / report with the court 26(f)(2)
- 14 days for initial disclosures from 26(a)(1)(C) conference (unless an order says otherwise)

7. How much time MUST exist between a 26(f) conference and a scheduling order or conference?
39 days or 69 days, so atleast 39
90 - 21 = 69
60 - 21 = 39

9. Can a scheduling order be modified ? If yes what circumstances

Yes, but only for good cause and with the judge’s consent.

10. What must a scheduling order have?

16(b)(3)(B)

11. When must initial disclosures be made?

26(a)(1)(c)