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

4 Questions to Ask Before Moving for a Discovery Protective Order

153000711In California, civil discovery is “self-executing,” i.e., a party demanding discovery doesn’t need prior court approval, and the responding party may object instead of providing the requested information. An objection often ends the matter, but sometimes it doesn’t, and the party resisting discovery has to consider moving for a protective order. Continue reading

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