Local Rule 26.1: Discovery in Civil Cases

Rule 26.1 Discovery in Civil Cases

(A) Discovery Materials Not To Be Filed; Exceptions. A party may conduct discovery but must not file a discovery request or response or a deposition transcript unless:

(1) the Court orders the filing;

(2) the material is needed for determination of a pending motion or issue; or

(3) the material is admitted into evidence at a trial or hearing.

(B) Place of Depositions. Unless the Court orders otherwise for cause,

(1) a party who asserts a claim for affirmative relief—other than costs and attorney's fees—can be required to appear once in this District for a deposition; and

(2) any other party can be required to appear for a deposition only where a nonparty witness could be required to appear.

(C) Objections to Written Discovery Requests. An objection to an interrogatory, production request, or admission request must be set out specifically for the individual interrogatory, production request, or admission request; an objection cannot be set out generally for an entire set of discovery requests. Boilerplate objections are strongly disfavored.

(D) Motions To Compel. A discovery motion must frame the dispute clearly and, if feasible, must, for each discovery request at issue:

(1) quote the discovery request verbatim;

(2) quote each objection specifically directed to the discovery request; and

(3) set out the reasons why the discovery should be compelled.