Discovery

Know your opponent

Eight defense tricks in employment litigation

From Issue: 2021 August

You can use PMK testimony in place of expert testimony to demonstrate how the employer failed to protect a disabled employee’s rights

A guide to compelling their production over defendant’s objections

From Issue: 2018 April

How the crafty defense lawyer hides things by avoiding the details in Requests for Production of Documents

You must thoroughly research social media on every case and brief your clients on how their postings may be used against them

From Issue: 2019 April

Making sense of “who ran the red light?”

From Issue: 2017 May

Steps to take control over the litigation and get what you need from discovery

Application of attorney-client and work-product privileges to corporate incident reports and employee-witness statements

A deposition subpoena for the production of business records is a useful tool in gathering evidence

How to start your federal case discovery as quickly as possible by countering the defense attempt to delay it

From Issue: 2020 March

You’ve served the subpoena duces tecum but still don’t have the documents – here’s your game plan

From Issue: 2019 April

What you don’t learn from a police report may be just what you need to prove liability and identify other defendants