Paragraph (4) of subsection (a) of Code Section 9-11-37 applies to the award of expenses incurred in relation to the motion. If the request is refused, the person may move for a court order. Upon request, a person not a party may obtain, without the required showing, a statement concerning the action or its subject matter previously made by that person. A party may obtain, without the required showing, a statement concerning the action or its subject matter previously made by that party. In ordering discovery of such materials when the required showing has been made, the court shall protect against disclosure of the mental impressions, conclusions, opinions, or legal theories of an attorney or other representative of a party concerning the litigation. #Audiofinder mac trialSubject to paragraph (4) of this subsection, a party may obtain discovery of documents and tangible things otherwise discoverable under paragraph (1) of this subsection and prepared in anticipation of litigation or for trial by or for another party or by or for that other party's representative (including his attorney, consultant, surety, indemnitor, insurer, or agent) only upon a showing that the party seeking discovery has substantial need of the materials in the preparation of his case and that he is unable without undue hardship to obtain the substantial equivalent of the materials by other means. For purposes of this paragraph, an application for insurance shall not be treated as part of an insurance agreement Information concerning the insurance agreement is not by reason of disclosure admissible in evidence at trial. A party may obtain discovery of the existence and contents of any insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in the action or to indemnify or reimburse for payments made to satisfy the judgment. It is not ground for objection that the information sought will be inadmissible at the trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery or to the claim or defense of any other party, including the existence, description, nature, custody, condition, and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter. Unless otherwise limited by order of the court in accordance with this chapter, the scope of discovery is as follows: Unless the court orders otherwise under subsection (c) of this Code section, the frequency of use of these methods is not limited. Parties may obtain discovery by one or more of the following methods: depositions upon oral examination or written questions written interrogatories production of documents or things or permission to enter upon land or other property for inspection and other purposes physical and mental examinations and requests for admission.
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