Discovery

Using motions to compel and protective orders to stop the defense’s games

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

From Issue: 2020 December

Getting the corporate incident report and witness statements

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

Lyssa A. Roberts

From Issue: 2019 October

Seven ways to quash a subpoena

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

Jonathan Bakhsheshian

From Issue: 2017 October

Using the Rule 26 conference to start your discovery

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

Jeff Westerman

From Issue: 2020 March

Turn up the heat on your record subpoenas

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

Clifton N. Smoot

From Issue: 2019 April

Protecting your client’s privacy in discovery

Be prepared to keep your client’s irrelevant personal history out of discovery whenever possible; that felony conviction, however, may be a bridge too far

Jeffrey Greenman

From Issue: 2018 March

Person most knowledgeable depositions in employment disability discrimination

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

Griselda S. Rodriguez

From Issue: 2019 October

Company accident reports

A guide to compelling their production over defendant’s objections

Andrew Owen

From Issue: 2018 April

Using the teeth of the statute to get the most out of RFPs

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

Patrick Nolan

From Issue: 2017 October

Using social media to build — and protect — your case

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

Steven A. Kronenberg

From Issue: 2019 April

To stop or to go?

Making sense of “who ran the red light?”

Allen Bourgeois
Matthew Manjarrez

From Issue: 2017 May

New discovery requirements, sanctions, and procedures for 2020

Production of documents, electronic exchange of interrogatories and requests for admission, and use of federal discovery procedures in state courts

Stephanie Taft

From Issue: 2020 February