CMC is scheduled in early June. Should I be actively preparing and/or delivering *any* Discovery components (Deposition requests; interrogatories; Requests for Admission) to Defendant *prior* to CMC? If Discovery happens only *after* the CMC, which goes first - Interrogatories, RFAs, POD; does order matter?
I have already started in on the design of interrogatories that refer back to my allegations. As I understand it, I am permitted 35 Interrogatories (with possibility of expanding that by Court permission). As my Defendant (a financial institution: this is a foreclosure fraud case) is being sued for three causes of action, do I get 35 interrogatories per Cause of Action, or am I limited to 35 interrogatories, in toto?
As regards Requests for Admission, is there an upper limit to RFAs?