Order should include all outstanding discovery or indicate that discovery is complete. Discovery requests and responses are not filed with the court.The party propounding or responding to discovery requests must serve every party to the action. Each party is allowed to take up to ten depositions without the judge's permission. Defense counsel should keep two goals in mind in pursuing discovery. The foremost goal, of course, is to obtain information. Rule 31.10 provides for the ability to seek leave (permission) from a judge to examine a non-party. Comply with a standing order of which the person does not have actual notice. Unless required to be filed for issuance of a subpoena for a deposition, a notice of deposition need not be filed. This rule if the person served does not complete and return the Notice and.