The North Carolina discovery plan
North Carolina has no discovery-control Levels — no election on the pleading, no tiered budget. The plan is built the classic way: the scope sentence, the 26(f) meeting machinery, and the response clocks in the deadline registry.
The scope — in the rule's own shape
G.S. 1A-1, Rule 26(b)(1)
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 of any other party.
- NO discovery-control Levels: North Carolina has no TRCP 190 analog — there is no level election on the pleading and no rule-imposed discovery period by tier.
- NO 2015-federal proportionality rewrite: the scope clause is the classic subject-matter formulation; proportionality battles run through Rule 26(c) protective orders, not the scope sentence.
The 26(f) machine — meeting → conference → plan
G.S. 1A-1, Rule 26(f), (f1)
- 1
No earlier than 40 DAYS after the complaint is filed, any party's attorney (or an unrepresented party) may request a discovery meeting — the request itself is a docketable act.
- 2
The meeting's subject is discovery INCLUDING electronically stored information — ESI planning is in the rule's own text, not an import.
- 3
The court may order a discovery conference and enter a discovery plan; the plan is the court's order and governs over default timing.
Which weapons to serve, and when, is strategy — the campaign engine sequences it inside the workspace, and every strike ties to an element of a claim or it does not exist.