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provisions: DESIR-005

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DESIR-005 127 NY-SC-9JD-DESIR V Discovery Discovery is not stayed by dispositive motion or ADR. Production deadlines presumptively 5:00 p.m. EST and within 10 days of an order if not specified otherwise. Requesting a Discovery Conference: do not wait until compliance conference; request by email to Part e-mail with subject line 'Discovery Conference Request: [Index number, case name]' with brief statement (max 500 words) of unresolved dispute(s). Non-requesting party may respond within 24 hours by replying all with 500 words or less. Individual Pre-Conference Letters: if permission granted, parties shall e-file letters of no more than 1,500 words at least 48 hours before conference. Privilege: objecting party must serve privilege log of responsive documents with production, identifying all redacted and withheld documents by bates-stamp numbers, dates, authors, recipients, subject matter, and privileges asserted; failure to serve privilege log is waiver absent good cause. ESI: counsel must discuss ESI with clients and then meet and confer with opposing counsel, reaching agreement on scope, location, format, custodians, costs, timing, and filing sharing techniques. Depositions: scheduled depositions cannot be adjourned without Court approval; parties must conduct depositions per CPLR 3115 and Rule 221. Discovery motions not permitted unless specifically authorized or directed by Court; must be brought by Order to Show Cause.   ["discovery-scheduling", "discovery-disputes", "depositions"] ["CPLR 3115", "Rule 221 Uniform Rules"] 9 Rockland supreme part_rules
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