Automatic (initial) Disclosures
At the initial stage of discovery, a party must, even without the request of the other side disclose certain things. First, each party must disclose the name, address and phone number of each individual likely to have discoverable information that the party plans to use in its case. Second, a party must provide a copy, or at least a description of all documents and tangible things in that party’s possession that it plans to use in its case.
If a party declines to furnish certain documents or information based on a claim of attorney/client privilege or work product immunity, the party must make the claim expressly and provide a privilege log that describes the nature of the documents or information being withheld. That way the opposing party will be able to at least question the validity of the privilege or work product claim by analyzing the nature of the information.