Rule 6-2 Prompt Completion and Presumptive Limits

(a) Discovery Period and Presumptive Limits. The discovery period and presumptive limits on discovery shall be governed by the following:

(1) A party may begin discovery before the entry of the Case Management Order, but the presumptive discovery period shall be set in the Case Management Order. The Court shall presume that an eight-month discovery period should be sufficient to complete all fact discovery. This period may be lengthened or shortened in consideration of the claims and defenses of a particular case, but a significantly longer discovery period shall require a showing of good cause (e.g., the parties demonstrate a need for expert discovery).

(2) Each party shall ensure that discovery is completed within the time specified in the Case Management Order. A party should serve interrogatories, requests for production, and requests for admission early enough that answers and responses can be completed before the end of the discovery period.

(3) Any motion that seeks to extend the discovery period or take discovery beyond the limits in the Case Management Order shall be made before the current deadline for discovery. The motion to extend the discovery period shall explain the good cause that justifies the relief sought and demonstrate that the parties have diligently pursued discovery to date.

(b) Written Discovery. Unless otherwise permitted by the Court, a party may serve no more than 50 interrogatories on each party. Each subpart of an interrogatory counts as a separate interrogatory for purposes of this limit. The same limit shall apply to requests for admission.

(c) Depositions Upon Oral Examination – Duration and Number. Unless otherwise permitted by the Court or stipulated by the parties, a deposition shall be limited to one day of seven hours. A party may take no more than 15 fact depositions in the absence of an order by the Court. For purposes of counting depositions taken by any party, for depositions conducted pursuant to OCGA § 9-11-30 (b) (6), each period of seven hours of testimony shall count as a single deposition, regardless of the number of designees presented during that seven-hour period.

(d) Agreement, Reduction, and Modification of Limits. The parties should attempt to agree, where appropriate, on reductions to the presumptive limits in this rule. Absent agreement of the parties, the presumptive limits may be increased only upon a showing of good cause.