Briefly describe the scope and type(s) of discovery available (e.g., depositions, interrogatories, etc.):
Each party, with its initial pleading, shall serve copies of all documents in the possession, custody or control of the party that are likely to bear significantly on any claim or defense. In pre-status conference, parties may request the production of additional document, seek leave to conduct a reasonable number of depositions. However, interrogatories should not be routinely granted. Parties may also obtain expert witnesses, but they are also subject to depositions.