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In ordering discovery of such materials when the required showing has been made, the court shall protect against disclosure of the mental impressions, conclusions, opinions, or legal theories of an attorney or other representative of a party concerning the litigation.
Rule 1.303 - Time for motion or answer to petition 1. 303(1) Unless otherwise provided, the defendant, respondent, or other party shall serve, and within a reasonable time thereafter file, a motion or answer within 20 days after the service of the original notice and petition upon such party.
An attorney can issue a subpoena without a court file being opened, but if the clerk issues a blank subpoena, a court file must be opened and will collect a $50 fee. Rule 1.1702(5). A court file will also be opened for any motions relating to the subpoena and the clerk will collect a $50 fee then as well.
(2) Production of documents. In addition to document disclosures required under rule 1.500(1)(a), each side may serve no more than 10 requests for production on any other side under rule 1.512.
Unless otherwise ordered by the court, no deposition, notice of deposition, interrogatory, request for production of documents, request for admission, or response, document or thing produced, or objection thereto shall be filed with the clerk.
Rule 1.509(2) adds to the permissible scope of interrogatories the amounts claimed for items of damages approved by the court in Gordon v. Noel, 356 N.W. 2d 559 (Iowa 1984), and the addresses of trial witnesses.
In addition, rule 1.943 allows for voluntary dismissal of the plaintiff's petition without prejudice once as a matter of right. Id. r. 1.943.