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The notice shall state the time and place for taking the deposition and the name and address of each person to be examined, if known, or if the name is not known, a general description sufficient for identification.
37. On notice to other parties and all affected persons, a party may move for an order compelling discovery. The motion shall include a certification that the movant has in good faith conferred or attempted to confer with the person or party failing to make discovery in an effort to obtain it without court action.
Rule 34 - Producing Documents, Electronically Stored Information, and Tangible Things, or Entering Onto Land, for Inspection and Other Purposes (A) Scope. Subject to the scope of discovery provisions of Civ.
The scope of discovery includes all matters that are relevant to the subject matter of the lawsuit, even if that matter is not admissible at trial, just as long as it ?appears reasonably calculated to lead to the discovery of admissible evidence?.
Discovery may be permitted by deposition upon oral examination or written questions; written interrogatories; production of documents or tangible things or permission to enter upon land or other property; and requests for admissions.
Rule 32 - Use of Depositions in Court Proceedings (A) Use of depositions. Every deposition intended to be presented as evidence must be filed at least one day before the day of trial or hearing unless for good cause shown the court permits a later filing.
A defendant shall make his demand for discovery within twenty- one days after arraignment or seven days before the date of trial, whichever is earlier, or at such reasonable time later as the court may permit.
When a person claiming to have a cause of action or a defense to an action commenced against him, without the discovery of a fact from the adverse party, is unable to file his complaint or answer, he may bring an action for discovery, setting forth in his complaint in the action for discovery the necessity and the ...