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Rule 26(b)(5) governs discovery of electronically stored information and provides that a party may initially refuse to produce electronically stored information from a source that is not reasonably accessible because of undue burden or cost.
Id. Rule 81 requires use of a special summons which commands that the defendant appear and defend at a specific time and place set by order of the court and informs him or her that no answer is necessary.
A party against whom a claim, counter-claim, or cross-claim is asserted or a declaratory judgment is sought may, at any time, move with or without supporting affidavits for a summary judgment in his favor as to all or any part thereof. (c) Motion and Proceedings Thereon.
Rule 55 - Default (a) Entry. When a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend as provided by these rules and that fact is made to appear by affidavit or otherwise, the clerk shall enter his default. (b) Judgment.
On a motion for a new trial in an action tried without a jury, the court may open the judgment if one has been entered, take additional testimony, amend findings of fact and conclusions of law or make new findings and conclusions, and direct the entry of a new judgment.
Replies should be succinctly stated. If the response to a fact is ?undisputed,? the reply should also state ?undisputed.? If you contend that despite a response of ?disputed,? the non-moving party has failed to raise a genuine dispute of material fact, you should succinctly state why.
Rule 37 - Failure to Make or Cooperate in Discovery: Sanctions (a)Motion for Order Compelling Discovery. A party, upon reasonable notice to other parties and all persons affected thereby, may apply for an order compelling discovery.
Rule 56 - Summary Judgment (a)Motions for Summary Judgment. A party may move for summary judgment subsequent to the commencement of any proceeding under these rules except in actions for divorce or in actions for custody or visitation or for criminal contempt.