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All discovery shall be completed no later than 60 days before trial (Rule 218). Failure to appear may result in dismissal for want of prosecution or entry of a default order.

Disclosure of any matter obtained by discovery is not conclusive, but may be contradicted by other evidence. (k)Reasonable Attempt to Resolve Differences Required. The parties shall facilitate discovery under these rules and shall make reasonable attempts to resolve differences over discovery.

201(b)(3). For a person to be considered a consultant, he or she must have ?been retained or specially employed in anticipation of litigation or preparation for trial but who is not to be called at trial.? Id.

(1) Protective Orders. The court may at any time on its own initiative, or on motion of any party or witness, make a protective order as justice requires, denying, limiting, conditioning, or regulating discovery to prevent unreasonable annoyance, expense, embarrassment, disadvantage, or oppression.

Discovery depositions taken under the provisions of this rule may be used only: (1) for the purpose of impeaching the testimony of the deponent as a witness in the same manner and to the same extent as any inconsistent statement made by a witness; (2) as a former statement, pursuant to Illinois Rule of Evidence 801(d)( ...

(1)Petition. (i) A person or entity who wishes to engage in discovery for the sole purpose of ascertaining the identity of one who may be responsible in damages may file an independent action for such discovery.