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(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 Rules 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.