UCCR 1.10

(A) All discovery must be completed within ninety days from service of an answer by the

applicable defendant. If the pleading is one to which no answer is required, either party

desiring discovery may timely move the court for an order scheduling discovery to extend

or shorten the time for discovery, according to the issues involved. If no such motion is

filed, then discovery shall be completed ninety days from completion of service of process

on all defendants.

(B) Additional discovery time may be allowed with leave of court upon written motion

setting forth good cause for the extension. Absent special circumstances the court will not

allow testimony at trial of an expert witness who was not designated as an expert witness

to all attorneys of record at least sixty days before trial.

(C) When responding to discovery requests, interrogatories, requests for production, and

requests for admission, the responding party shall, as part of the responses, set forth

immediately preceding the response the question or request to which such response is

given. Responses shall not be deemed to have been served without compliance with this

subdivision.

(D) No motion to compel shall be heard unless the moving party shall incorporate in the

motion a certificate that movant has conferred in good faith with the opposing attorney in

an effort to resolve the dispute and has been unable to do so. Motions to compel shall quote

verbatim each contested request, the specific objection to the request, the grounds for the

objection, and the reasons supporting the motion.