Extract to table

Supplementation shall occur on a rolling basis as additional information becomes available and, in any event, each party shall serve supplemental initial disclosures at least thirty (30) days before the close of fact discovery — i

Scope of discovery Discovery in this action shall be conducted in phases as described below and shall be governed by the principles of relevance and proportionality set forth in Federal Rule of Civil Procedure 26(b)(1)

Phase 1 shall encompass the service and response to interrogatories, requests for production of documents, and requests for admission

Responses and objections to all written discovery shall be due thirty (30) days from service, subject to reasonable extensions by written agreement of the parties

Phase 2 shall encompass the depositions of party witnesses, corporate representative depositions under Rule 30(b)(6), and third-party witness depositions

Deposition Logistics: Unless otherwise agreed by the parties, depositions of party witnesses shall be taken at the offices of the deponent's counsel in the city of counsel's choice