The proposed rules sought to reduce the presumptive number of depositions to five from ten, each deposition to one day of six hours instead of seven hours, the presumptive number of interrogatories to 15 from 25, and to create a presumptive limit of 25 requests for admission where none previously existed
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Reducing the presumptive number of interrogatories to 15 from 25
These Protocols were developed over the course of eighteen months by a joint committee consisting of NELA members and members of the management bar. The project was supervised by Judge John G. Koeltl (S.D.N.Y.), and the final protocols were adopted by the Judicial Conference Advisory Committee...
Initial Discovery Protocols For Employment Cases_Nov 2011.pdf