Colorado — Centennial
Respond & protect.
The defensive side of Colorado discovery, stated from the loaded corpus only.
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The first shield is the cap
"prior to issuance of the Case Management Order shall not exceed the limitations established by C.R.C.P. 26(b)(2)"
C.R.C.P. 26(d) (as printed in Rule Change 2024(03))
Early over-service runs into the order-carried pre-CMO cap before anything else.
The privileges are statutory — and the LLP has parity
Spousal privilege
"a husband shall not be examined for or against his wife without her consent nor a wife for or against her husband without his consent"
Attorney-client privilege — EXTENDED TO LICENSED LEGAL PARAPROFESSIONALS
"An attorney or licensed legal paraprofessional shall not be examined without the consent of the attorney's or licensed legal paraprofessional's client as to any communication made by the client"
Physician-patient privilege
"A physician, surgeon, or registered professional nurse duly authorized to practice his or her profession pursuant to the laws of this state or any other state shall not be examined without the consent"
If a motion comes, the clock is order-carried
21 days — "The responding party shall have 21 days after the filing of the motion or such lesser or greater time as the court may allow in which to file a responsive brief." C.R.C.P. 121 § 1-15(1)(b) (as printed in Rule Change 2024(03))
Raw count, Rule-6 boundary stated — the registry computes it.
Named at the boundary
Protective orders (C.R.C.P. 26(c)), objections and responses under Rules 33/34/36, and the sanctions machinery of Rule 37 are vendor-published rule text — named here, never paraphrased. Preservation has its own absence page.