Complete Standard Discovery — Limits on Standard Discovery:

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Deposition Request for Request for Days to
Tier Hours Interrogatories Production Admission Complete Summary of Civil
1 3 0 5 5 120 Process
File Complaint 2 15 10 10 10 180
Plead Tier 1, 2, 3 3 30 20 20 20 210

120 Days 7 Days Disclosure of Experts by Certify Ready for Trial

Party w/ Burden of Proof

Serve Complaint 7 Days 28 Days

If Needed
and Summons Before Trial
Selection by Party w/o BOP
File Stipulation File Motion for
of Expert Deposition or
for Extraordinary Extraordinary
21 or 30 Expert Report Pretrial Disclosures
Discovery Discovery
Days
28 Days
14 Days

7 Days
File Answer Depose Expert or Before Trial
Plead Tier 1, 2, 3 Motion Granted Serve Expert Report
for Counter Claim
7 Days Pretrial Objections

Disclosure of Experts by
14 Days
Motion Denied Party w/o Burden of Proof

7 Days
Plaintiff’s
Initial Disclosures Selection by Party w/ BOP Pretrial Conference
Complete
of Expert Deposition or
Extraordinary
Expert Report
42 Days Discovery
28 Days

Defendant’s Depose Expert or

Initial Disclosures Serve Expert Report Trial

Revised October 2016