Flores (P) accused Southern (D) of mining activities that harmed the environment for over 40 years. The parties submitted a joint Report and Proposed Discovery Plan as required by Rule 26(f). They stipulated to adjourn the making of the initial disclosures required by subsections (A)-(C) until the Court has ruled on a dispositive motion D filed. The parties are in disagreement whether the disclosure called for by Rule 26(a)(1)(D) should be similarly adjourned. P refused to waive disclosure of insurance policies required by Rule 26(a)(1)(D). D objects to disclosure regarding effort, expense and drafting a confidentiality agreement because if D is successful in its motion, these additional actions would be unnecessary.