(1) depositions by oral examination or written questions under Rules 30 and 31, respectively;

(2) written interrogatories under Rule 33;

(3) requests for production of documents or things or permission to enter onto land or other property for inspection and other purposes, under Rule 34;

(4) physical and mental examinations under Rule 35;

(5) requests for admission under Rule 36; and

(6) subpoenas for production of documentary evidence or for inspection of premises under Rule 45(c).

(1) Scope in General. Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable.

(2) Limitations on Frequency and Extent.

(3) Work Product and Witness Statements.

(4) Expert Discovery.

(5) Notice of Nonparty at Fault. No later than 150 days after filing its answer, a party must serve on all other parties--and should file with the court--a notice disclosing any person: (A) not currently or formerly named as a party in the action; and (B) whom the party alleges was wholly or partly at fault under A.R.S. § 12-2506(B). The notice must disclose the identity and location of the nonparty allegedly at fault, and the facts supporting the allegation of fault. A party who has served a notice of nonparty at fault must supplement or correct its notice if it learns that the notice was or has become materially incomplete or incorrect and if the additional or corrective information has not otherwise been disclosed to the other parties through the discovery process or in writing. A party must supplement or correct its notice of nonparty at fault under this rule in a timely manner, but in no event more than 30 days after it learns that the notice is materially incomplete or incorrect. The trier of fact may not allocate any percentage of fault to a nonparty who is not disclosed in accordance with this rule except on stipulation of all the parties or on motion showing good cause, reasonable diligence, and lack of unfair prejudice to all other parties.

(6) Claims of Privilege or Protection of Work-Product Materials.

(1) Generally. A party or any person from whom discovery is sought may move for a protective order in the court where the action is pending--or alternatively, on matters relating to a deposition, the court in the county where the deposition will be taken. A person receiving a request to preserve electronically stored information may move for a protective order in the court in the county where the action is pending, as provided in Rule 45.2(d)(2). Subject to Rule 26(c)(4), the court may, for good cause, enter an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or more of the following:

(2) Ordering Discovery. If a motion for a protective order is wholly or partly denied, the court may, on terms that are just, order that any party or person provide or permit discovery.

(3) Awarding Expenses. Rule 37(a)(5) applies to the award of expenses on a motion for a protective order.

(4) Confidentiality Orders.

(5) Sealing Orders. Any request under Rule 26(c) for an order to file a document under seal must comply with, and is subject to the requirements of, Rule 5.4.

(1) When Applicable. Unless the court decides to permit full briefing, this procedure applies to all disputes between parties to the action that could properly be addressed in motions for protective order under Rule 26(c) or motions to compel discovery or disclosure under Rule 37(a). The filings in a Rule 26(d) proceeding are not motions.

(2) Joint Statement of Discovery or Disclosure Dispute. When the parties have a dispute that could properly be addressed under Rule 26(c) or Rule 37(a), they must file with the court a joint statement of discovery or disclosure dispute. The joint statement must not exceed 3 pages of explanatory text, with each party entitled to submit one and one-half pages of that text. The parties must also attach a good faith consultation certificate complying with Rule 7.1(h) and may not attach exhibits. The purposes of the joint statement are to notify the court of the dispute, and to make a record of the discovery or disclosure sought. Briefing on the dispute is permitted only if ordered by the court.

(3) Expedited Hearing by the Court. Unless the court orders otherwise, the parties may jointly contact the court by telephone to request a hearing on the joint statement of discovery dispute. The court should schedule the matter at the earliest convenient time, whether by telephone or in person.

(4) Resolution by Minute Entry. The court must issue a minute entry setting forth the resolution of the discovery dispute. After resolution, a party may file with the court those materials necessary to create a record of the discovery or disclosure the court permitted or denied.

(5) Depositions. Nothing in Rule 26(d) limits the ability of the parties to seek the intervention of the court by telephone during a deposition without the necessity of filing a written statement of discovery dispute.

(1) Generally. In deciding any motion or Rule 26(d) proceeding addressing whether sources of electronically stored information are not reasonably accessible because of undue burden or expense as provided in Rule 26(b)(2)(B)(i), the court must determine:

(2) Affidavit of Burden or Expense. A party or person contending that the disclosure or discovery of electronically stored information should be disallowed or limited because of undue burden or expense must file with their joint statement under Rule 26(d)(2) or their motion for protective order under Rule 26(c) an affidavit describing the burden and estimating the expense that would be incurred.

(3) Burden or Expense--Factors. In addition to the factors in Rule 26(b)(1), in determining whether the party or person opposing the discovery or disclosure would incur undue burden or expense, the court must consider:

(4) Good Cause--Factors. In addition to the factors in Rule 26(b)(1), in determining whether good cause is shown, the court may consider:

(5) Specifying Conditions. The court may impose conditions on the discovery or disclosure that include:

(1) a party may not seek discovery from any source--including nonparties--before that party serves its initial disclosure statement under Rule 26.1;

(2) methods of discovery may be used in any sequence; and

(3) discovery by one party does not require any other party to delay its discovery.

(1) Generally. A party who has responded to an interrogatory, request for production, or request for admission must supplement or correct its response if it learns that the response was or has become materially incomplete or incorrect and if the additional or corrective information has not otherwise been disclosed to the other parties during the discovery process or in writing.

(2) Timing. A party must supplement or correct a discovery response under this rule in a timely manner, but in no event more than 30 days after it learns that the response is materially incomplete or incorrect. If the party knows or reasonably should know the additional or corrective information is relevant to a hearing or deposition scheduled to occur in less than 30 days, the party must supplement or correct the discovery response reasonably in advance of the hearing or deposition.