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Under the best-evidence rule, an ?original writing, recording, or photograph is required? to prove its contents. Minn. R. Evid.
Most important is Rule 30.04(a), which is intended to constrain the conduct of attorneys at depositions. The rule limits deposition objections to concise statements that are directed to the record and not so suggesting a possible answer to the deponent.
Subject to the provisions of Rule 26.02(e) a party may obtain discovery of documents and tangible things otherwise discoverable pursuant to Rule 26.02(b) and prepared in anticipation of litigation or for trial by or for another party or by or for that other party's representative (including the other party's attorney, ...
Rule 33. Interrogatories may, without leave of court, be served upon any party after service of the summons and complaint. No party may serve more than a total of 50 interrogatories upon any other party unless permitted to do so by the court upon motion, notice and a showing of good cause.
Rule 9.02, subd. 1(5) requires written notice of any defense - other than not guilty - on which the defendant intends to rely at the trial, along with the names and addresses of the witnesses the defendant intends to call at the trial.
37.05Failure to Preserve Electronically Stored Information (3) dismiss the action or enter a default judgment.
Rule 37.03 - Failure to Disclose, to Supplement an Earlier Response or to Admit (a) Failure to Disclose or Supplement. If a party fails to provide information or identify a witness as required by Rule 26.01 or .