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Leave to amend a pleading shall be liberally granted in furtherance of the ends of justice. In granting leave to amend, the court may make such provision for notice thereof and opportunity to make response as the court may deem reasonable and proper.
Counsel of record shall make a reasonable effort to confer before giving notice of a motion to resolve the subject of the motion and to determine a mutually agreeable hearing date and time.
[1] Rule 1.8(a) states the general principle that all transactions between client and lawyer should be fair and reasonable to the client.
Absent leave of court, if a brief in support of a motion is five or fewer pages in length, the required notice and the brief shall be filed and served at least 14 days before the hearing and any brief in opposition to the motion shall be filed and served at least seven days before the hearing.
(1) A party is under a duty promptly to amend and/or supplement all responses to discovery requests directly addressed to (A) the identity and location of persons having knowledge of discoverable matters, and (B) the identity of each person expected to be called as an expert witness at trial, the subject matter on ...
Pursuant to Rule (b) of the Rules of the Supreme Court of Virginia, absent leave of court, civil motions in Virginia ?shall be in writing and served at least seven days before the hearing.? Rule (b).
Depositions Upon Oral Examination. (a) When Depositions May Be Taken. ? After commencement of the action, any party may take the testimony of any person, including a party, by deposition upon oral examination.
If a defendant files no other pleading in response than the answer, it must be filed within the applicable 21-day, 60-day, or 90-day period specified in this Rule. An answer must respond to the paragraphs of the complaint. A general denial of the entire complaint or plea of the general issue is not permitted.