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  • 26(f).
    It includes drafting notes and alternate and optional clauses.
    Note that some courts have their own templates for these submissions.
    Rule 26(f) requires federal litigants to confer early in a case, develop a discovery plan, and submit to the court a written report outlining the plan.

  • What is the 10 deposition limit?

    Rule 30(a)(2)(A)(i) limits the number of depositions to 10 “by the plaintiffs, or by the defendants, or by the third-party defendants.” In other words, the limit is 10 depositions per each side.
    The parties can stipulate to exceed this limitation or a party can seek leave of court. (See Rule 30(a)(2)(A).)

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