R. 4:104-2. — Timing of Discovery

a. A party may not seek discovery from any source before the parties have conferred as required by R. 4:103-2, except when expressly authorized by these rules, by stipulation, or by court order.

b. More than 35 days after the summons and complaint are served, a request under R. 4:18 may be delivered: (1) to that served party by another party or (2) by that served party to any plaintiff or to any other party that has been served. Any R. 4:18 requests served before the R. 4:103-2 conference shall be deemed served on the day of the first R. 4:103-2 conference.