Avoid the Dangers of Missing E-Data

Most discovery requests will require production of electronic data. Even if you’re tech savvy, it’s better not to go it alone because the sanctions for missing something can be huge, as Delta Airlines and defense counsel in a trademark case have found out the hard way. Plus you have an ethical duty to competently handle e-discovery—including bringing technical consultants on board when needed. Continue reading

Deposing the Doctor: Why Do It and How Much Will It Cost?

ThinkstockPhotos-79085832In cases in which there are medical issues, you’ll need to decide whether to depose the treating physician. Here are some considerations to keep in mind as you make this call. Continue reading

5 Reasons to Use Inspection Demands

five_108523216With a written demand for inspection or production, a party can get the opposing party to produce documents or things for inspection, copying, testing, and sampling. CCP §2031.010. This can be a powerful discovery tool with at least five advantages over other discovery methods. Continue reading

Develop a Routine: Stock Questions to Ask in Every Deposition

185496686Every case is different, but there are some questions you should ask in most every deposition. Know your routine questions and use them. Continue reading

How Can Someone Be Deposed Twice in the Same Case?

ThinkstockPhotos-501707257Generally, you can’t compel someone to attend a deposition if he or she has been previously deposed in the same case. But there are 5 exceptions to this rule. Continue reading

Size Up Your Adversary

ThinkstockPhotos-494299501When it comes to litigating a case, your client’s objectives are only half the story. If you want to gain an advantage, you’ll also need to successfully assess your adversary’s goals, capabilities, and willingness to fight. Continue reading

6 Things to Know About Interrogatory Responses

ThinkstockPhotos-158217439So, you’ve been hit with interrogatories. Before you start working on responses, review these 6 points. Continue reading

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