(a) Relief Under FRCP 26(c) or 37(a)(3).

If relief is sought under FRCP 26(c) or 37(a)(3), concerning any interrogatories, requests for
production or inspection, requests for admissions, answers to interrogatories or responses to
requests for admissions, copies of the relevant portions of the interrogatories, requests, answers,
or responses in dispute shall be attached to the motion.

(b)  Definitions and Rules of Construction.

The full text of the definitions and rules of construction set forth in this paragraph is deemed
incorporated by reference into all discovery requests, but shall not preclude (i) the definition of
other terms specific to the particular litigation, (ii) the use of abbreviations or (iii) a more
narrow definition of a term defined in this paragraph. This rule is not intended to broaden or
narrow the scope of discovery permitted by the FRCP.

The following definitions apply to all discovery requests:

      (1)   Communication. The term "communication" means the transmittal of information (in the form of
             facts, ideas, inquiries, or otherwise).

      (2)   Document. The word "document" is synonymous - and equal in scope - to the use of this term in
             FRCP 34(a). A draft of a non-identical copy is a separate document within the meaning of this term.

      (3)   Identify (With Respect to Persons). When referring to a person, to "identify" means to give,
             to the extent known, the person’s full name, present or last known address, e- mail address, and
             telephone number, and when referring to a natural person, additionally, the present or last known
             place of employment. Once a person has been identified in accordance with this subparagraph, only
             the name of that person need be listed in response to subsequent discovery requesting the
             identification of that person.

      (4)   Identify (With Respect to Documents). When referring to documents, “to identify” means to
             give, to the extent known, the (i) type of document; (ii) general subject matter; (iii) date of the
             document; and (iv) author(s), addressee(s), and recipient(s).

      (5)   Parties. The terms “plaintiff” and “defendant” as well as a party’s full or abbreviated name
             or pronoun referring to a party mean the party and, where applicable, its officers, directors,
             employees, partners, corporate parent, subsidiaries, or affiliates. This definition is not intended
             to impose a discovery obligation on any person who is not a party to the litigation.

      (6)   Person. The term “person” is defined as any natural person or business, legal, or
             governmental entity or association.

      (7)   Concerning. The term “concerning” means relating to, referring to, describing, evidencing, or constituting.

(c)  Protective Orders.

Upon motion by any party demonstrating good cause, the Court may enter a protective order or any
other appropriate order.

(d)  Authentication of Documents.

A party’s production of a document in response to written discovery authenticates the document for
use against that party in any pretrial proceeding or at trial unless within 14 days or a longer or
shorter period ordered by the Court, after the producing party has actual notice that the document
will be used – the party objects to the authenticity of the document, or any part of it, stating
the specific basis for objection. An objection must be either on the record or in writing and must
have a good faith factual and legal basis. An objection made to the authenticity of only part of a
document does not affect the authenticity of the remainder. If objection is made, the party
attempting to use the document should be given a reasonable opportunity to establish its
authenticity.

(e)  Discovery.

Discovery shall not be filed with the Clerk. Absent exceptional circumstances, no motions relating
to discovery, including motions under FRCP 26(c), 29, and 37, shall be filed after the expiration
of the discovery deadline, unless they are filed within 7 days after the discovery deadline and
pertain to conduct occurring during the final 7 days of discovery. Written discovery is not timely
unless the response to that discovery would be due before the discovery deadline. The responding
party has no obligation to respond or object to written discovery if the response and objection
would not be due until after the discovery deadline. Depositions must be completed before the
discovery deadline. Any notices served before the discovery deadline scheduling depositions after
the discovery deadline will not be enforced.