PreTrial Scheduling Coming Right Up -- Asserting My Rights?

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I have a Pretrial Scheduling Conference on the very-immediate horizon (u.t.a.h.).


I want to be certain that I assert every procedural right I have, and will consult our Rules.


However, I'm hoping to get tips, things to look out for, rights to preserve, etc..


(I'm not sure if I'm dealing with an OC or a JDB --- Plaintiff [CA] has said accounts were "assigned" to them --- but that could mean more than one thing?)


Thank you!   


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It looks like we might be discussing rule 26(a) in the scheduling conference -- including Initial Disclosures.


I sent my initial disclosures off a couple of weeks ago.  The plaintiff has never responded to mine -- and has never given me any of his.... even though the complaint was filed a few months ago. (Plaintiff's Initial Disclosures were due 14 days after I filed my answer.)


I just filed a Motion to Preclude plaintiff's Initial Disclosures [based on rule 26(a)] -- but plaintiff has not had much time to reply yet.


I feel like I had better object to any scheduling modifications under rule 26(a) that arise during the conference tomorrow --- but I need some valid grounds to do it upon.....


.....any ideas?

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