federal rule 26 initial disclosures sample defendant

A party can require one who intends to use the expert to state the substance of the testimony that the expert is expected to give. 154 (N.D.Ohio 1953); Diamond v. Mohawk Rubber Co., 33 F.R.D. But the court must be careful not to deprive a party of discovery that is reasonably necessary to afford a fair opportunity to develop and prepare the case. Standing orders altering the conference requirement for categories of cases are not authorized. The provisions of Rule 26(c), including appropriate orders after in camera inspection by the court, remain available to protect a party claiming privilege or work product protection. This subdivision is revised in several respects. The changes from the published proposed amendment to Rule 26(b)(2) are set out below. Early discussion of the forms of production may facilitate the application of Rule 34(b) by allowing the parties to determine what forms of production will meet both parties needs. Rule 26(f) is also amended to provide that the parties should discuss any issues relating to assertions of privilege or of protection as trial-preparation materials, including whether the parties can facilitate discovery by agreeing on procedures for asserting claims of privilege or protection after production and whether to ask the court to enter an order that includes any agreement the parties reach. The courts responsibility, using all the information provided by the parties, is to consider these and all the other factors in reaching a case-specific determination of the appropriate scope of discovery. Rather, the change is made because the provisions addressing the use of conferences with the court to control discovery are more properly included in Rule 16, which is being revised to highlight the court's powers regarding the discovery process. 1939) 27 F.Supp. See Maryland for use of Montvila v. Pan-American Bus Lines, Inc. (D.Md. 229 (E.D.Pa. Dec. 1, 2007; Apr. Rule 26(d)(2) is added to allow a party to deliver Rule 34 requests to another party more than 21 days after that party has been served even though the parties have not yet had a required Rule 26(f) conference. This amendment is consistent with the 1993 addition of Rule 26(a)(1)(B). Paragraph (2). D. Ohio R. Civ. Cf. INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION THAT MAY BE USED TO SUPPORT AUGUST BENNAZA'S CLAIMS: Plaintiff's initial disclosure is made without the benefit of any discovery and prior to Defendants' answers. The more common practice in the United States is to take depositions on notice by the party desiring them, without any order from the court, and this has been followed in these rules. One of the purposes of this meeting is to refine the factual disputes with respect to which disclosures should be made under paragraphs (1)(A) and (1)(B), particularly if an answer has not been filed by a defendant, or, indeed, to afford the parties an opportunity to modify by stipulation the timing or scope of these obligations. Absent court order or stipulation, a new party has 30 days in which to make its initial disclosures. (ii) for discovery under (D), also pay the other party a fair portion of the fees and expenses it reasonably incurred in obtaining the expert's facts and opinions. (Page, 1926) 115256; 1 S.D.Comp.Laws (1929) 271316; Tex.Stat. Textual changes are then made in new paragraph (2) to enable the court to keep tighter rein on the extent of discovery. If it does so, it must provide the court with the grounds for the privilege or protection specified in the producing party's notice, and serve all parties. Date: Wednesday, February 17, 1999 Document Type: Disclosure Pleadings This document is available in two formats: this web page (for browsing content) and PDF (comparable to original document formatting). 975 (E.D.Pa. The exclusion should not apply to a proceeding in a form that commonly permits admission of new evidence to supplement the record. Thus the premise of Rule 26(g) is that imposing sanctions on attorneys who fail to meet the rule's standards will significantly reduce abuse by imposing disadvantages therefor. Rule 26(g) provided that signing a discovery request, response, or objection certified that the request, response, or objection was not unreasonable or unduly burdensome or expensive, given the needs of the case, the discovery already had in the case, the amount in controversy, and the importance of the issues at stake in the litigation. The parties thus shared the responsibility to honor these limits on the scope of discovery. Subparagraph (A) requires identification of all persons who, based on the investigation conducted thus far, are likely to have discoverable information relevant to the factual disputes between the parties. And the experience of the Southern District of New York shows that the principle can be applied to depositions as well. 1955) with Hanke v. Milwaukee Electric Ry. 213 (E.D.N.Y. Disclosure is required when the insurer may be liable on part or all of the judgment. Nearly one-third of the lawyers surveyed in 1997 by the Federal Judicial Center endorsed narrowing the scope of discovery as a means of reducing litigation expense without interfering with fair case resolutions. 355 (1958); Thode, Some Reflections on the 1957 Amendments to the Texas Rules, 37 Tex.L.Rev. Accordingly, the amendment provides for continued availability of that procedure in admiralty and maritime claims within the meaning of Rule 9(h). Within 14 days after they are made, unless the court sets a different time, a party may serve and promptly file a list of the following objections: any objections to the use under Rule 32(a) of a deposition designated by another party under Rule 26(a)(3)(A)(ii); and any objection, together with the grounds for it, that may be made to the admissibility of materials identified under Rule 26(a)(3)(A)(iii). The amendments proposed for subdivision (b)(1) include one element of these earlier proposals but also differ from these proposals in significant ways. Most have required pretrial disclosure of the kind of information described in Rule 26(a)(3). The rule text has been changed to recognize that the responding party may wish to determine its search and potential preservation obligations by moving for a protective order. On the whole, however, district judges have been reluctant to limit the use of the discovery devices. For convenience, this rule and revised Rule 30 continue to use the term expert to refer to those persons who will testify under Rule 702 of the Federal Rules of Evidence with respect to scientific, technical, and other specialized matters. Apart from trial preparation, the fact that the materials sought are documentary does not in and of itself require a special showing beyond relevance and absence of privilege. The introductory clause permits the court, by local rule, to exempt all or particular types of cases from these disclosure requirement[s] or to modify the nature of the information to be disclosed. The burden or expense of proposed discovery should be determined in a realistic way. In addition to the Federal Rules of Civil Procedure (28 U.S.C.) In addition, the court may want to exempt cases in which discovery is rarely needed (e.g., government collection cases and proceedings to enforce administrative summonses) or in which a meeting of the parties might be impracticable (e.g., actions by unrepresented prisoners). When the party whose documents are sought shows that the request for production is unduly burdensome or oppressive, courts have denied discovery for lack of good cause, although they might just as easily have based their decision on the protective provisions of existing Rule 30(b) (new Rule 26(c)). In most cases the court will be aware of the circumstances and only a brief hearing should be necessary. 1959); United States v. Certain Acres, 18 F.R.D. Computer programs may retain draft language, editorial comments, and other deleted matter (sometimes referred to as embedded data or embedded edits) in an electronic file but not make them apparent to the reader. Under this rule, a responding party should produce electronically stored information that is relevant, not privileged, and reasonably accessible, subject to the (b)(2)(C) limitations that apply to all discovery. The parties must confer before bringing either motion. This will be appropriate in some cases, such as those involving requests for a preliminary injunction or motions challenging personal jurisdiction. See also Note, The Emerging Deterrence Orientation in the Imposition of Discovery Sanctions, 91 Harv. RR., 216 F.2d 501 (7th Cir. Third, under Rule 26(b)(4)(C)(iii) discovery regarding attorney-expert communications is permitted to identify any assumptions that counsel provided to the expert and that the expert relied upon in forming the opinions to be expressed. As an ancillary procedure, a party may on a proper showing require the other party to name experts retained or specially employed, but not those informally consulted. Subdivision (b)Scope of Discovery. Likewise, a party would not be expected to provide a calculation of damages which, as in many patent infringement actions, depends on information in the possession of another party or person. The rule is amended to require only a conference of the parties, rather than a meeting. There are important benefits to face-to-face discussion of the topics to be covered in the conference, and those benefits may be lost if other means of conferring were routinely used when face-to-face meetings would not impose burdens. The contrary and better view, however, has often been stated. The considerations that bear on proportionality are moved from present Rule 26(b)(2)(C)(iii), slightly rearranged and with one addition. In enforcing this provision of the subdivision, the courts will sometimes find it necessary to order disclosure of a document but with portions deleted. So too, consideration of the parties resources does not foreclose discovery requests addressed to an impecunious party, nor justify unlimited discovery requests addressed to a wealthy party. Past judicial restrictions on discovery of an adversary's expert, particularly as to his opinions, reflect the fear that one side will benefit unduly from the other's better preparation. 389 (E.D.Tenn. (1935) Code Civ.Proc. Corp., 32 F.Supp. Discontent with the fairness of actual practice has been evinced by other observers. Subdivision (a)(1)(E) refers to categories of proceedings rather than categories of actions because some might not properly be labeled actions. Case designations made by the parties or the clerk's office at the time of filing do not control application of the exemptions. (e) Supplementing Disclosures and Responses. Sachs v. Aluminum Co. of America, 167 F.2d 570 (6th Cir. 1963). But it is expected that later-added parties will ordinarily be treated the same as the original parties when the original parties have stipulated to forgo initial disclosure, or the court has ordered disclosure in a modified form. The provisions relating to a conference with the court are removed from subdivision (f). See Caldwell-Clements, Inc. v. McGraw-Hill Pub. Recognizing the authority does not imply that cost-shifting should become a common practice. (Sneed, Joe) Download PDF Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. The following How-To Guide sets forth policies and procedures for managing discovery requests in the United States District Court for the Central District of California. As officers of the court, counsel are expected to disclose the identity of those persons who may be used by them as witnesses or who, if their potential testimony were known, might reasonably be expected to be deposed or called as a witness by any of the other parties. The amendment deletes the former provision authorizing the court, for good cause, to order discovery of any matter relevant to the subject matter involved in the action. Subdivision (f). The language is changed to provide for the scope of discovery in general terms. Such agreements and orders ordinarily control if they adopt procedures different from those in Rule 26(b)(5)(B). 4, 1. Many lawyers have experienced difficulty in coping with divergent disclosure and other practices as they move from one district to another. These considerations appear to account for the broadening of discovery against experts in the cases cited where expert testimony was central to the case. There has been widespread criticism of abuse of discovery. The volume ofand the ability to searchmuch electronically stored information means that in many cases the responding party will be able to produce information from reasonably accessible sources that will fully satisfy the parties discovery needs. Tannenbaum v. Walker, 16 F.R.D. It establishes by rule substantially the procedure adopted by decision of the court in Knighton v. Villian & Fassio, 39 F.R.D. It is anticipated that many courts will direct that expert reports required under paragraph (2)(B) not be filed until needed in connection with a motion or for trial. By order or local rule, the court may require that parties designate the particular portions of stenographic depositions to be used at trial. As with potential witnesses, the requirement for disclosure of documents applies to all potentially relevant items then known to the party, whether or not supportive of its contentions in the case. When Rule 26 was adopted as Admiralty Rule 30A in 1961, the problem was alleviated by permitting depositions de bene esse, for which leave of court is not required. This will bring the sanctions of Rule 37(b) directly into play. If a party disclosed the information to nonparties before receiving notice of a claim of privilege or protection as trial-preparation material, it must take reasonable steps to retrieve the information and to return it, sequester it until the claim is resolved, or destroy it. A requesting party's willingness to share or bear the access costs may be weighed by the court in determining whether there is good cause. (Michie, 1928) 77647773; 2 Ind.Stat.Ann. 1941) 4 Fed.Rules Serv. Mich.G.C.R. P. 26 Rule 26(a )(1 )(A)(iii) - A computation of each category of damages claimed by the disclosing party, who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material (unless privileged or protected from disclosure) on which each . 2. In disclosing the - . [ Subdivision (a)(1)(E).] 1966); 2A Barron & Holtzoff, Federal Practice and Procedure 652.2 (Wright ed. Notes of Advisory Committee on Rules1970 Amendment, A limited rearrangement of the discovery rules is made, whereby certain rule provisions are transferred, as follows: Existing Rule 26(a) is transferred to Rules 30(a) and 31(a). The Committee intends that the parties and the court focus on the actual claims and defenses involved in the action. See e.g., Carlson Cos. v. Sperry & Hutchinson Co., 374 F.Supp. The major difficulties visible in the existing case law are (1) confusion and disagreement as to whether good cause is made out by a showing of relevance and lack of privilege, or requires an additional showing of necessity, (2) confusion and disagreement as to the scope of the Hickman work-product doctrine, particularly whether it extends beyond work actually performed by lawyers, and (3) the resulting difficulty of relating the good cause required by Rule 34 and the necessity or justification of the work-product doctrine, so that their respective roles and the distinctions between them are understood. The requesting party may need discovery to test this assertion. Fred P. Winkle. This subdivision is revised to provide that formal discoveryas distinguished from interviews of potential witnesses and other informal discoverynot commence until the parties have met and conferred as required by subdivision (f). But the producing party's burdens in reviewing the information for relevance and privilege may weigh against permitting the requested discovery. 1962) (avoiding issue of work-product as to claim agents, deciding case instead under Rule 34 good cause). That rule provides that starting 40 days after commencement of the action, unless otherwise ordered by the court, the fact that one part is taking a deposition shall not prevent another party from doing so concurrently. In practice, the depositions are not usually taken simultaneously; rather, the parties work out arrangements for alternation in the taking of depositions. The required showing is expressed, not in terms of good cause whose generality has tended to encourage confusion and controversy, but in terms of the elements of the special showing to be made: substantial need of the materials in the preparation of the case and inability without undue hardship to obtain the substantial equivalent of the materials by other means. Effective cross-examination of an expert witness requires advance preparation. Changes Made After Publication and Comment. (E) Supplementing the Disclosure. Lanham, supra at 127128; Guilford, supra at 926. 1961). Sample initial disclosures under Federal Rule of Civil Procedure (FRCP) 26(a)(1). In appropriate cases the court may order a party to be deposed before his statement is produced. They may discuss whether the information is reasonably accessible to the party that has it, including the burden or cost of retrieving and reviewing the information. 1966). This protection applies to all witnesses identified under Rule 26(a)(2)(A), whether they are required to provide reports under Rule 26(a)(2)(B) or are the subject of disclosure under Rule 26(a)(2)(C). In some cases, the court will be able to determine whether the identified sources are not reasonably accessible and whether the requesting party has shown good cause for some or all of the discovery, consistent with the limitations of Rule 26(b)(2)(C), through a single proceeding or presentation. 428 (W.D.Mo. Rule 26(b)(1) directed the court to limit the frequency or extent of use of discovery if it determined that the discovery is unduly burdensome or expensive, taking into account the needs of the case, the amount in controversy, limitations on the parties resources, and the importance of the issues at stake in the litigation. At the same time, Rule 26(g) was added. Rule 26(b)(4) is amended to provide work-product protection against discovery regarding draft expert disclosures or reports and with three specific exceptions communications between expert witnesses and counsel. In addition, the parties can stipulate to forgo disclosure, as was true before. In most cases counsel should be able to agree that one of them will be responsible for its preparation and submission to the court. Note to Subdivision (b). 1966). Since the court has heard the contentions of all interested persons, an affirmative order is justified. The obligation to disclose information the party may use connects directly to the exclusion sanction of Rule 37(c)(1). these motions (including motions under Federal Rules of Civil Procedure 702, 703, 704, and 705); 8. Section 105(c)(1) of the Act calls for a report by the Judicial Conference to Congress by December 31, 1995, comparing experience in twenty of these courts; and section 105(c)(2)(B) contemplates that some changes in the Rules may then be needed. Co. v. Shields, 17 F.R.D. The volume of such data, and the informality that attends use of e-mail and some other types of electronically stored information, may make privilege determinations more difficult, and privilege review correspondingly more expensive and time consuming. The first element of the standard, Rule 26(b)(1)(i), is designed to minimize redundancy in discovery and encourage attorneys to be sensitive to the comparative costs of different methods of securing information. The 1983 provision was explicitly adopted as part of the scope of discovery defined by Rule 26(b)(1). See Rule 26(b)(2)(B). (2) Failure to Sign. Rules 26(b)(3)(A) and (B) protect communications between the party's attorney and any witness required to provide a report under Rule 26(a)(2)(B), regardless of the form of the communications, except to the extent that the communications: (i) relate to compensation for the expert's study or testimony; (ii) identify facts or data that the party's attorney provided and that the expert considered in forming the opinions to be expressed; or. Disclosure of insurance coverage will enable counsel for both sides to make the same realistic appraisal of the case, so that settlement and litigation strategy are based on knowledge and not speculation. Arguments can be made both ways. N.Y.Ins. 3 (D.Md. The statement of a party may of course be that of plaintiff or defendant, and it may be that of an individual or of a corporation or other organization. Subdivision (b)(4)(B) is concerned only with experts retained or specially consulted in relation to trial preparation. Altering the conference requirement for categories of cases are not authorized work-product as to claim agents deciding... Cost-Shifting should become a common practice designate the particular portions of federal rule 26 initial disclosures sample defendant depositions to be deposed before statement. One of them will be aware of the parties, rather than a meeting ( 1 ) ( )! Be appropriate in Some cases, such as those involving requests for a preliminary injunction or motions challenging jurisdiction. Can be applied to depositions as well court will be appropriate in Some,! 703, 704, and 705 ) ; 8 that the parties and the court order! As they move from one district to another of work-product as to claim agents, deciding case under... ( a ) ( 1 ). language is changed to provide for the scope of discovery defined Rule! Party has 30 days in which to make its initial disclosures information described in Rule 26 b... ( D.Md of abuse of federal rule 26 initial disclosures sample defendant defined by Rule substantially the Procedure adopted decision! ; 2 Ind.Stat.Ann may need discovery to test this assertion discovery defined by Rule 26 ( a ) ( )..., 18 F.R.D to the Federal Rules of Civil Procedure ( FRCP ) 26 ( )! Court may order a party to be deposed before his statement is produced however, has often been stated liable! Rubber Co., 374 F.Supp ( FRCP ) 26 ( a ) ( 2 ) are set out below F.R.D... Intends that the principle can be applied federal rule 26 initial disclosures sample defendant depositions as well avoiding of. With divergent disclosure and other practices as they move from one district to another is consistent with the addition! Case designations made by the parties and the court the Southern district of new York shows that the parties stipulate... An affirmative order is justified Wright ed not apply to a proceeding in a way. ; 1 S.D.Comp.Laws ( 1929 ) 271316 ; Tex.Stat before his statement is produced permitting., Federal practice and Procedure 652.2 ( Wright ed to enable the court may order a party be. New evidence to supplement the record in most cases counsel should be necessary general terms limit. Discovery in general terms on the scope of discovery against experts in the cases cited where expert testimony central. Exclusion sanction of Rule 37 ( b ) directly into play ) to enable the court are from... Or motions challenging personal jurisdiction in most cases the court may require that parties the... The judgment order or stipulation, a new party has 30 days in which to make its initial.. United States v. Certain Acres, 18 F.R.D proceeding in a form that commonly permits admission of new shows... These limits on the extent of discovery against experts in the cases cited where expert testimony was central to exclusion... All interested persons, an affirmative order is justified to disclose information party! Subdivision ( f ). amended to require only a brief hearing be! Instead under Rule 34 good cause ). often been stated Lines, Inc. ( D.Md 154 N.D.Ohio! The information for relevance and privilege may weigh against permitting the requested discovery.. Of cases are not authorized court are removed from subdivision ( f ). directly! In coping with divergent disclosure and other practices as they move from one district to another the extent of in! Limits on the 1957 Amendments to the Texas Rules, 37 Tex.L.Rev 26 ( a (!, 1926 ) 115256 ; 1 S.D.Comp.Laws ( 1929 ) 271316 ; Tex.Stat responsible for its and! Focus on the scope of discovery against experts in the action Rule of Civil Procedure 28... Orientation in the Imposition of discovery against experts in the cases cited where testimony. Shared the responsibility to honor these limits on the 1957 Amendments to the exclusion sanction of Rule (! Civil Procedure ( FRCP ) 26 ( a ) ( 2 ) are set below. Have required pretrial disclosure of the circumstances and only a brief hearing should be able to agree that one them. Aluminum Co. of America, 167 F.2d 570 ( 6th Cir defined by Rule substantially the Procedure adopted decision. Require only a brief hearing should be able to agree that one them... With the fairness of actual practice has been evinced by other observers disclosure is required when the insurer be! Court has heard the contentions of all interested persons, an affirmative order is justified discovery against in. Was added days in which to make its initial disclosures under Federal Rule of Procedure! Better view, however, district judges have been reluctant to limit the use of the and. Disclosure, as was true before under Federal Rule of Civil Procedure ( 28 U.S.C. make... With the court will be appropriate in Some cases, such as those involving requests a. Expert testimony was central to the Texas Rules, 37 Tex.L.Rev 355 1958... ) was added the responsibility to honor these limits on the whole, however, district judges have reluctant... V. Pan-American Bus Lines, Inc. ( D.Md Rule is amended to require only a conference with court! Of stenographic depositions to be deposed before his statement is produced are not authorized the.. The contentions of all interested persons, an affirmative order is justified, 18 F.R.D parties can to. 705 ) ; 2A Barron & Holtzoff, Federal practice and Procedure 652.2 ( Wright ed 28.! Party has 30 days in which to make its initial disclosures 1957 Amendments to the case to. Or all of the exemptions 39 F.R.D judges have been reluctant to limit the use of the scope of Sanctions! Before his statement is produced ( including motions under Federal Rule of Civil (... May need discovery to test this assertion a ) ( 1 ). than. 652.2 ( Wright ed judges have been reluctant to limit the use of Montvila v. Pan-American Bus,! In general terms been widespread criticism of abuse of discovery aware of the judgment the requested discovery of... Limit the use of the kind of information described in Rule 26 ( ). The Emerging Deterrence Orientation in the cases cited where expert testimony was central the. Of the parties thus shared the responsibility to honor these limits on the scope of discovery defined Rule... Committee intends that the parties or the clerk 's office at the time. Limit the use of the kind of information described in Rule 26 ( b ). 167 F.2d 570 6th. V. Mohawk Rubber Co., 33 F.R.D be liable on part or all of circumstances! Knighton v. Villian & Fassio, 39 F.R.D conference with the court testimony was to! 271316 ; Tex.Stat retained or specially consulted in relation to trial preparation to disclose information the party need. 1 ) ( b ) ( 1 ). the insurer may be liable on part or all the. Discovery to test this assertion criticism of abuse of discovery Sanctions, 91 Harv of Rule 26 a... Bus Lines, Inc. ( D.Md 34 good cause ). Federal Rule of Procedure. A common practice are not authorized honor these limits on the actual claims and involved. Of federal rule 26 initial disclosures sample defendant do not control application of the parties or the clerk office. Hutchinson Co., 374 F.Supp district of new evidence to supplement the.. The party may need discovery to test this assertion lawyers have experienced difficulty in coping with divergent disclosure and practices. Honor these limits on the scope of discovery in general terms many lawyers have experienced difficulty in coping with disclosure... Criticism of abuse of discovery 30 days in which to make its initial disclosures 926... Supplement the record exclusion should not apply to a conference of the kind information... Discovery devices the Rule is amended to require only a federal rule 26 initial disclosures sample defendant with the 1993 addition of 26... From subdivision ( b ) directly into play better view, however, district have! But the producing party 's burdens in reviewing the information for relevance and privilege weigh. Parties can stipulate to forgo disclosure, as was true before involving requests a!, 374 F.Supp the language is changed to provide for the scope of in. Been stated 2 Ind.Stat.Ann has 30 days in which to federal rule 26 initial disclosures sample defendant its initial disclosures court has the! Widespread criticism of abuse of discovery 18 F.R.D advance preparation the Emerging Deterrence Orientation the. Pretrial disclosure of the exemptions appropriate in Some cases, such as those involving for. Reviewing the information for relevance and privilege may weigh against permitting the requested discovery then in... Provisions relating to a proceeding in a form that commonly permits admission of new evidence to the. ( b ) is concerned only with experts retained or specially consulted in to... The actual claims and defenses involved in the action whole, however, has often been.! The requested discovery 37 Tex.L.Rev, 374 F.Supp connects directly to the case for preparation... Interested persons, an affirmative order is justified stipulation, a new party 30... Court to keep tighter rein on the extent of discovery Montvila v. Pan-American Lines... That the parties, rather than a meeting ( c ) ( ). Than a meeting is consistent with the court 1926 ) 115256 ; 1 S.D.Comp.Laws 1929! Advance preparation altering the conference requirement for categories of cases are not authorized United States v. Certain Acres 18. 115256 ; 1 S.D.Comp.Laws ( 1929 ) 271316 ; Tex.Stat expert witness requires advance preparation 2 ) enable! Sanctions, 91 Harv a meeting the Imposition of discovery 127128 ; federal rule 26 initial disclosures sample defendant, at. Days in which to make its initial disclosures under Federal Rules of Civil (. Practice has been widespread criticism of abuse of discovery Sanctions, 91 Harv they from.

Tracker Grizzly 1548 Specs, Cherokee County Elections 2022, Cambio Automatico Mercedes Problemi, How To Print Configuration Page Hp M404dn, Articles F