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A Rule 30(b)(6) notice must (1) provide the date, time, and place for taking the deposition; (2) specify the name and address of the entity being deposed; (3) set forth with reasonable particularity the matters for examination; (4) indicate the method by which the testimony will be recorded and whether documents are

On a motion to compel discovery or for a protective order, the person responding to a subpoena must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the Court nevertheless may order discovery from such sources if the requesting party shows good cause.

The Court may order an action dismissed, sua sponte, upon notice of the Court, for failure of a party diligently to prosecute the action, for failure to comply with any rule, statute, or order of the Court, or for any other reason deemed by the Court to be appropriate.

A party has standing to move for a protective order with respect to discovery directed at a non-party on the basis of annoyance, embarrassment, oppression, or undue burden or expense that the moving party will bear.

Rule 11 - Signing of pleadings, motions, and other papers: Representations to Court, sanctions (a) Signature. Every pleading, motion, and other paper shall be signed by at least 1 attorney of record in the attorney's individual name, or, if the party is not represented by an attorney, shall be signed by the party.

A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing or trial.

R. 45(a)(1).) A party, or the attorney responsible for the issuance and service of a subpoena, must take reasonable steps to avoid imposing undue burden or expense on the person subject to the subpoena.

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Exhibit and Witness List - AO-187(DE). Creating exhibit lists is a critical part of preparing for a federal civil trial.22 Exchange of witness lists, statements, and exhibits. For each plaintiff's exhibit, fill in a description of the exhibit. Indicate whether the exhibit is Full (the parties agree) or ID. You may choose to submit an exhibit list that includes the exhibit number, number of pages of the exhibit, and a description of the exhibit. • All exhibits and list of potential witnesses must be served on all parties in the case. You may choose to submit an exhibit list that includes the exhibit number, number of pages of the exhibit, and a description of the exhibit. In addition, an Exhibit List of all exhibits must be completed. (iii) any exhibits that will be used to summarize or support them;.

Delaware Exhibit and Witness List - (DE)

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