Ga. Unif. Super. Ct. R. 5.4

(1) The parties may agree to an early planning discovery conference, the judge may order the

parties to hold an early planning discovery conference, or a party may petition the court for an

early planning discovery conference. The conference may be held in the county in which the

action is pending or at such other place or by such other means as agreeable to the court. A

discovery conference may be held by telephone, by video conference, or in person, or a

combination thereof, unless the court orders the parties to attend in person. During an early

planning discovery conference, the parties shall:

a. Consider the nature and basis of the parties’ claims and defenses and the possibilities

of settling the case;

b. Resolve any issues regarding the scope of preservation of information;

c. Discuss the preparation of a discovery plan; and

d. Discuss any such issues as are relevant to the case.

(2) After an early planning discovery conference, the parties may submit an agreed upon

discovery plan within 14 days of the meeting and may request a conference with the court

regarding the plan. Unless the parties agree otherwise, the attorney for the plaintiff shall be

responsible for submitting the discovery plan to the court. The discovery plan may include:

a. A statement of the issues in the case and a brief factual outline;

b. A schedule of discovery including discovery of electronically stored information;

c. A defined scope of preservation of information and appropriate conditions for

terminating the duty to preserve prior to the final resolution of the case;

d. The format by which electronically stored information will be produced; and

e. Sources of any stored information that is not reasonably accessible because of undue

burden or cost.

(3) If a discovery plan is not agreed upon, the parties may submit to the court within 14 days of

the meeting a joint report indicating the agreed upon parts of the discovery plan and the position

of each party on the parts upon which they disagree. The court shall confer in an appropriate

manner with the parties to resolve any outstanding issues.