Rule 1.501.Discovery methods
Division V: Discovery and Inspection · Last amended January 1, 2015 · Last verified July 15, 2026
Full Text of Rule 1.501
Comment
Rule 1.501 (3). The rule makes the certification of conference requirement apply to all discovery motions. A similar provision is contained in rule 1.504 (3) governing motions for protective order and in rule 1.517 (5) governing sanctions and motions to compel. Telephonic conferences satisfy the conference requirement of these rules. [Court Order August 28, 2014, effective January 1, 2015]
Plain-English Summary
Rule 1.501(1) lists the discovery methods available beyond the disclosures Rule 1.500 already requires: depositions on oral examination or written questions, written interrogatories, requests to produce documents or things or to enter land for inspection, physical and mental examinations, and requests for admission, all subject to the timing rules in Rule 1.505. Rule 1.501(2) directs courts and parties to construe and apply these discovery rules broadly, to secure a just, speedy, and inexpensive resolution of the case and to give the parties access to all relevant facts.
Rule 1.501(3) sets a good-faith baseline: responses to discovery requests, however they're made, must address the actual substance of what's being asked rather than dodge it in form. Any discovery motion presented to the court has to include a certification that the movant personally spoke, or tried to speak, with the other affected parties to resolve the dispute first, identifying when that happened. Rule 1.501(4) offers a convenient alternative to a notarized oath: a matter that would normally need to be sworn can instead use a specific certification, under penalty of perjury, in the form the rule provides.
The official Comment explains that this conferral-certification requirement isn't unique to Rule 1.501 — the same obligation applies to protective-order motions under Rule 1.504 and to sanctions and compel motions under Rule 1.517, and a telephone call between the parties satisfies it.
Frequently Asked Questions
What discovery methods are available in an Iowa civil lawsuit?
Depositions on oral examination or written questions, written interrogatories, requests for production of documents or things or entry on land, physical and mental examinations, and requests for admission.
Do I have to try to work things out with the other side before filing a discovery motion?
Yes. Rule 1.501(3) requires any discovery motion to include a certification that you personally spoke with, or tried to speak with, the other affected parties in a good-faith effort to resolve the dispute, and to state when that happened.
Can a phone call satisfy the requirement to confer before filing a discovery motion?
Yes. The official Comment to Rule 1.501 confirms that telephonic conferences satisfy the conference requirement.
Can I avoid notarizing a discovery response by using an alternative certification?
Yes. Rule 1.501(4) allows a matter requiring an oath to be satisfied instead by an unsworn written statement certifying, under penalty of perjury, that the statement is true and correct.
How should courts interpret Iowa's discovery rules generally?
Rule 1.501(2) directs that they be liberally construed, administered, and employed to secure a just, speedy, and inexpensive determination of the case and to give parties access to all relevant facts.