(a) Exchange of Records.
(1) Within five days of the date that plaintiff notifies the court pursuant to Rule 16(e) of these Rules that all served defendants have either answered or filed motions, plaintiff shall serve upon defendant copies of all of plaintiff’s available medical records relevant to the condition which is the subject matter of the action.
(2) Within ten days of the date of service by plaintiff of such records, each defendant shall serve upon plaintiff copies of all of plaintiff’s medical records relevant to the condition which is the subject matter of the action.
(3) In lieu of serving copies of the above-described records counsel may, before the date set for exchange of records, inquire of opposing counsel concerning the documents or electronically stored information which opposing counsel wishes produced and may then produce copies of only those records which are specifically requested.
(b) Discovery Limitations. Before the comprehensive pretrial conference contemplated by Rule 16(e) of these Rules, the parties may exchange the uniform interrogatories set forth in the Appendix and 10 additional non-uniform interrogatories. Any subparagraph of a non-uniform interrogatory will be treated as one non-uniform interrogatory. The parties may also submit a request for production of documents pursuant to Rule 34 of these Rules, requesting the following items:
1. A party’s wage information where relevant.
2. Written or recorded statements by any party or witness including reports or statements of experts.
3. Any exhibits intended to be used at trial.
4. Incident reports.
In addition, the depositions of the parties and any known liability experts may be taken. No other discovery is permitted before the comprehensive pretrial conference except pursuant to stipulation of the parties, or, upon motion and a showing of good cause. Stipulations for additional discovery shall not be unreasonably withheld.