It is not contemplated that requests for discovery conferences will be made routinely. The limitations of Rule 26(b)(2)(C) continue to apply to all discovery of electronically stored information, including that stored on reasonably accessible electronic sources. Accordingly, the deposition of an expert required by subdivision (a)(2)(B) to provide a written report may be taken only after the report has been served. Courts and parties should be willing to consider the opportunities for reducing the burden or expense of discovery as reliable means of searching electronically stored information become available. initial disclosures pursuant to Federal Rule of Civil Procedure Rule 26(a)(1). A party can require one who intends to use the expert to state the substance of the testimony that the expert is expected to give. Rule 26(c) (transferred from 30(b)) confers broad powers on the courts to regulate or prevent discovery even though the materials sought are within the scope of 26(b), and these powers have always been freely exercised. The rule does not demand an exhaustive investigation at this stage of the case, but one that is reasonable under the circumstances, focusing on the facts that are alleged with particularity in the pleadings. Rule 26(b)(1) has been amended to add a sentence to deal with the problem of over-discovery. The courts have not had an increase in motion business on this matter. Even in cases where the court is directed to issue a protective order, it may decline to do so if it finds that manifest injustice would result. (1937) ch. Rule 27. 1980); Note, Sanctions Imposed by Courts on Attorneys Who Abuse the Judicial Process, 44 U.Chi.L.Rev. The parties should also discuss at the meeting what additional information, although not subject to the disclosure requirements, can be made available informally without the necessity for formal discovery requests. The revision also dispels any doubt as to the power of the court to impose limitations on the length of depositions under Rule 30 or on the number of requests for admission under Rule 36. While far more limited, the experience of the few state and federal courts that have required pre-discovery exchange of core information such as is contemplated in Rule 26(a)(1) indicates that savings in time and expense can be achieved, particularly if the litigants meet and discuss the issues in the case as a predicate for this exchange and if a judge supports the process, as by using the results to guide further proceedings in the case. Yet, two verbally distinct doctrines have developed, each conferring a qualified immunity on these materialsthe good cause requirement in Rule 34 (now generally held applicable to discovery of documents via deposition under Rule 45 and interrogatories under Rule 33) and the work-product doctrine of Hickman v. Taylor, 329 U.S. 495 (1947). (1935) Code Civ.Proc. 154 (N.D.Ohio 1953); Diamond v. Mohawk Rubber Co., 33 F.R.D. Subdivision (b)(2). Rule 26(a)(1)(B) is amended to parallel Rule 34(a) by recognizing that a party must disclose electronically stored information as well as documents that it may use to support its claims or defenses. Even though a party may ultimately have to disclose in response to interrogatories or requests to admit, he is entitled to keep confidential documents containing such matters prepared for internal use. Rule 26(g) imposes an affirmative duty to engage in pretrial discovery in a responsible manner that is consistent with the spirit and purposes of Rules 26 through 37. "for each category of damages claimed by the disclosing partywho . When the review is of electronically stored information, the risk of waiver, and the time and effort required to avoid it, can increase substantially because of the volume of electronically stored information and the difficulty in ensuring that all information to be produced has in fact been reviewed. Costs have risen. By order or local rule, the court may require that parties designate the particular portions of stenographic depositions to be used at trial. In deciding the Hickman case, the Supreme Court appears to have expressed a preference in 1947 for an approach to the problem of trial preparation materials by judicial decision rather than by rule. (Michie, 1928) 77647773; 2 Ind.Stat.Ann. (Burns, 1933) 21501; Ky.Codes (Carroll, 1932) Civ.Pract. In addition to the disclosures required by Rule 26 (a) (1), a party must disclose to the other parties the identity of any witness it may use at trial to present evidence under Federal Rule of Evidence 702, 703, or 705. The responding party must also identify, by category or type, the sources containing potentially responsive information that it is neither searching nor producing. A party requesting discovery, for example, may have little information about the burden or expense of responding. The Committee has repeatedly been advised about the discovery difficulties that can result from efforts to guard against waiver of privilege and work-product protection. 90. Subdivision (b)(4)(B) is concerned only with experts retained or specially consulted in relation to trial preparation. (1) In General. a. Effective cross-examination of an expert witness requires advance preparation. July 1, 1963; Feb. 28, 1966, eff. It is expected that courts would, for example, exempt cases like Social Security reviews and government collection cases in which discovery would not be appropriate or would be unlikely. As with potential witnesses, the requirement for disclosure of documents applies to all potentially relevant items then known to the party, whether or not supportive of its contentions in the case. The signing requirement means that every discovery request, response, or objection should be grounded on a theory that is reasonable under the precedents or a good faith belief as to what should be the law. The 1993 Committee Note explained: [F]ormer paragraph (b)(1) [was] subdivided into two paragraphs for ease of reference and to avoid renumbering of paragraphs (3) and (4). Subdividing the paragraphs, however, was done in a way that could be read to separate the proportionality provisions as limitations, no longer an integral part of the (b)(1) scope provisions. July 1, 1966; Mar. E.g., Lauer v. Tankrederi, 39 F.R.D. See also Note, The Emerging Deterrence Orientation in the Imposition of Discovery Sanctions, 91 Harv. Rule 26 (a) (1) requires parties to provide the following information to each other party: (1) the name, address, and telephone number of each person "likely to have discoverable information that the disclosing party may use to support its claims or defenses, unless solely for . 1960). 1952) (condemnation). In considering the discovery needs of a particular case, the court should consider the factors described in Rule 26(b)(1). This Disclosure Statement is based upon investigation conducted and made available to undersigned counsel, as of this date. With that information, the parties can develop a discovery plan that takes into account the capabilities of their computer systems. Co. (C.C.A.2d, 1943) 139 F.(2d) 469; Mahler v. Pennsylvania R. Co. (E.D.N.Y. Dec. 1, 2007; Apr. Law 41. There is no reason to believe that unique circumstances justify varying these nationally-applicable presumptive limits in certain districts. An exception is also made as to expert trial witnesses in order to carry out the provisions of Rule 26(b)(4). In some instances, the opinions are explicit in relating expanded discovery to improved cross-examination and rebuttal at trial. This change reinforces the Rule 26(g) obligation of the parties to consider these factors in making discovery requests, responses, or objections. It also recommends changes in the Committee Note to explain that disclosure requirement. The requesting party has the burden of showing that its need for the discovery outweighs the burdens and costs of locating, retrieving, and producing the information. Co., 11 F.R.D. They may identify the various sources of such information within a party's control that should be searched for electronically stored information. This addition can be made without republication in response to public comments. Nor is the change intended to permit the opposing party to refuse discovery simply by making a boilerplate objection that it is not proportional. The rule does not attempt to define for each case what information must be provided when a party asserts a claim of privilege or work product protection. In addition, it recommends additional clarifying material in the Committee Note about the impact of the change on some commonly disputed discovery topics, the relationship between cost-bearing under Rule 26(b)(2) and expansion of the scope of discovery on a showing of good cause, and the meaning of relevant in the revision to the last sentence of current subdivision (b)(1). 4 Moore's Federal Practice 1154 (2d ed. It will conduce to settlement and avoid protracted litigation in some cases, though in others it may have an opposite effect. A party must make these disclosures at the times and in the sequence that the court orders. After receiving notice, each party that received the information must promptly return, sequester, or destroy the information and any copies it has. Because 26 (a) (2) specifies "any witness [a party] may use at trial . Subsection (A) creates a duty to disclose "the identity of any witness [a party] may use at trial to present evidence under Federal Rule of Evidence 702, 703 or 705.". As the Committee Note to the 2000 amendments observed, use of the reasonably calculated phrase to define the scope of discovery might swallow any other limitation on the scope of discovery. The 2000 amendments sought to prevent such misuse by adding the word Relevant at the beginning of the sentence, making clear that relevant means within the scope of discovery as defined in this subdivision . This otherwise redundant cross-reference has been added to emphasize the need for active judicial use of subdivision (b)(2) to control excessive discovery. The rules are amended by eliminating the general requirement of good cause from Rule 34 but retaining a requirement of a special showing for trial preparation materials in this subdivision. The obligation to provide pertinent information concerning withheld privileged materials applies only to items otherwise discoverable. If a broad discovery request is madefor example, for all documents of a particular type during a twenty year periodand the responding party believes in good faith that production of documents for more than the past three years would be unduly burdensome, it should make its objection to the breadth of the request and, with respect to the documents generated in that three year period, produce the unprivileged documents and describe those withheld under the claim of privilege. The lawyer even with the help of his own experts frequently cannot anticipate the particular approach his adversary's expert will take or the data on which he will base his judgment on the stand. An (a)(2)(B) report is required only from an expert described in (a)(2)(B). The inclusion of the opt out provision reflected the strong opposition to initial disclosure felt in some districts, and permitted experimentation with differing disclosure rules in those districts that were favorable to disclosure. Although there is no restriction on commencement of discovery in these cases, it is not expected that this opportunity will often lead to abuse since there is likely to be little or no discovery in most such cases. 1940) 3 Fed.Rules Serv. 1945) 9 Fed.Rules Serv. R. Civ. When the case was filed, the Clerk issued an Initial Scheduling Order, which set the date for exchanging Initial Disclosures. The new sentence is intended to encourage judges to be more aggressive in identifying and discouraging discovery overuse. The objective is to guard against redundant or disproportionate discovery by giving the court authority to reduce the amount of discovery that may be directed to matters that are otherwise proper subjects of inquiry. 1. 426 (W.D.Mo. 602.01; N.Y.C.P.L.R. The court must apply the standards in an even-handed manner that will prevent use of discovery to wage a war of attrition or as a device to coerce a party, whether financially weak or affluent. But a local court rule purporting to confer priority in certain classes of cases would be inconsistent with this subdivision and thus void. These limitations apply to discovery that is otherwise within the scope of subdivision (b)(1). New subdivision (a)(1)(E) excludes eight specified categories of proceedings from initial disclosure. There is, however, no obligation to provide supplemental or corrective information that has been otherwise made known to the parties in writing or during the discovery process, as when a witness not previously disclosed is identified during the taking of a deposition or when an expert during a deposition corrects information contained in an earlier report. The Rule 26(a)(1) initial disclosure provisions are amended to establish a nationally uniform practice. Ex parte preservation orders should issue only in exceptional circumstances. The Committee has been informed repeatedly by lawyers that involvement of the court in managing discovery is an important method of controlling problems of inappropriately broad discovery. The former provision for discovery of relevant but inadmissible information that appears reasonably calculated to lead to the discovery of admissible evidence is also deleted. (Page, 1926) 11497, 11526; Tex.Stat. The Hickman opinion drew special attention to the need for protecting an attorney against discovery of memoranda prepared from recollection of oral interviews. The existing subdivision, although in terms applicable only to depositions, is incorporated by reference in existing Rules 33 and 34. Revised Rule 37(c)(1) provides that only persons so listed may be used at trial to present substantive evidence. Imposition of a continuing burden reduces the proliferation of additional sets of interrogatories. A stipulation at an early meeting affording such a defendant at least 60 days after receiving the complaint in which to make its disclosures under subdivision (a)(1)a period that is two weeks longer than the time formerly specified for responding to interrogatories served with a complaintshould be adequate and appropriate in most cases. The Hickman case left this issue open since the statements in that case were taken by a lawyer. For these same reasons, courts are reluctant to make numerous exceptions to the rule. In each instance, the determination whether such information is discoverable because it is relevant to the claims or defenses depends on the circumstances of the pending action. In some cases, this discovery may go beyond the disclosure requirement in Rule 26(a)(2)(B)(vi). Subdivisions (a)(1)(C) and (D) are not changed. To the same effect, see Comment, Tactical Use and Abuse of Depositions Under the Federal Rules, 59 Yale L.J. In no instance does disclosure make the facts concerning insurance coverage admissible in evidence. 1, ECF No. It applies regardless of the form in which the draft is recorded, whether written, electronic, or otherwise. For a full analysis of the problem and strong recommendations to the same effect, see Friedenthal, Discovery and Use of an Adverse Party's Expert Information, 14 Stan.L.Rev. Existing Rule 26(c) is transferred to Rule 30(c). No change is made in the existing doctrine, noted in the Hickman case, that one party may discover relevant facts known or available to the other party, even though such facts are contained in a document which is not itself discoverable. the Rules . The conditions may also include payment by the requesting party of part or all of the reasonable costs of obtaining information from sources that are not reasonably accessible. The (a)(2)(C) disclosure obligation does not include facts unrelated to the expert opinions the witness will present. 1963); cf. (Vernon, 1928) arts. But if the parties continue to disagree, the discovery dispute could be brought before the court and the parties responsibilities would remain as they have been since 1983. In addition, the protection for draft expert disclosures or reports in proposed Rule 26(b)(4)(B) was changed to read "regardless of the form in which the draft is recorded." It is anticipated that many courts will direct that expert reports required under paragraph (2)(B) not be filed until needed in connection with a motion or for trial. (C) Witnesses Who Do Not Provide a Written Report. Existing Rules 26(d), (e), and (f) are transferred to Rule 32. 33.351, Case 1. The requesting party may need discovery to test this assertion. The required showing is expressed, not in terms of good cause whose generality has tended to encourage confusion and controversy, but in terms of the elements of the special showing to be made: substantial need of the materials in the preparation of the case and inability without undue hardship to obtain the substantial equivalent of the materials by other means. Except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B) or when the court orders otherwise, the parties must confer as soon as practicableand in any event at least 21 days before a scheduling conference is to be held or a scheduling order is due under Rule 16(b). Rule 26(b)(5)(B) is added to establish a parallel procedure to assert privilege or protection as trial-preparation material after production, leaving the question of waiver to later determination by the court. If the court later rules that documents for a seven year period are properly discoverable, the documents for the additional four years should then be either produced (if not privileged) or described (if claimed to be privileged). 26b.211, Case 3; Gitto v. Italia, Societa Anonima Di Navigazione (E.D.N.Y. Changes Made After Publication and Comment. The producing party must preserve the information until the claim is resolved. RR., 216 F.2d 501 (7th Cir. 946; Engl v. Aetna Life Ins. 4, 1. Rule 26(f) is also amended to direct the parties to discuss any issues regarding preservation of discoverable information during their conference as they develop a discovery plan. 1941) 5 Fed.Rules Serv. During the first 20 days after commencement of the actionthe period when defendant might assure his priority by noticing depositions16 percent of the defendants acted to obtain discovery. The disclosure obligation extends to any facts or data considered by the expert in forming the opinions to be expressed, not only those relied upon by the expert. In conferring, the parties must consider the nature and basis of their claims and defenses and the possibilities for promptly settling or resolving the case; make or arrange for the disclosures required by Rule 26(a)(1); discuss any issues about preserving discoverable information; and develop a proposed discovery plan. The addition of Rule 26(b)(4)(C) is designed to protect counsels work product and ensure that lawyers may interact with retained experts without fear of exposing those communications to searching discovery. (A) When Permitted. The Committee has considered a number of proposals to eliminate abuse, including a change in Rule 26(b)(1) with respect to the scope of discovery and a change in Rule 33(a) to limit the number of questions that can be asked by interrogatories to parties. The rule simply requires that the attorney make a reasonable inquiry into the factual basis of his response, request, or objection. Basic Standard. In the meantime, the present revision puts in place a series of disclosure obligations that, unless a court acts affirmatively to impose other requirements or indeed to reject all such requirements for the present, are designed to eliminate certain discovery, help focus the discovery that is needed, and facilitate preparation for trial or settlement. The right to object to initial disclosure is not intended to afford parties an opportunity to opt out of disclosure unilaterally. 45.5, 45.6 (Wright ed. 22, 1993, eff. (B) require the written report outlining the discovery plan to be filed less than 14 days after the parties conference, or excuse the parties from submitting a written report and permit them to report orally on their discovery plan at the Rule 16(b) conference. The parties are advised to strictly follow the letter and spirit of Rule 26(a)(1) in preparing their initial disclosures. Shall is replaced by must, does, or an active verb under the program to conform amended rules to current style conventions when there is no ambiguity. Subdivision (a)(1). 306.2. Pursuant to Fed.R.Civ.P. 1959) (patent); Cold Metal Process Co. v. Aluminum Co. of America, 7 F.R.D. Paragraph (5). 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