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How to Handle Improper Coaching at Deposition

One of the common problems at deposition is improper coaching of the deponent by counsel. If you’re the examining attorney, there are three steps you can take to handle this situation. Continue reading

Before Requesting Discovery, Have a Plan to Enforce It

When starting discovery, your focus is on the specific requests you will make. But don’t forget to have a plan to enforce your discovery efforts. Continue reading

Duty to Investigate Before Answering Interrogatories

looking_140478824Before you answer interrogatories, you have a duty to investigate. But what does that mean and how far do you have to go? Continue reading

3 Problem Areas for Interrogatory Responses

ThinkstockPhotos-527478227A party served with interrogatories under CCP §§2030.010–2030.410 has to respond by answering, producing writings, or objecting. And each answer has to be as “complete and straightforward as the information reasonably available to the responding party permits.” CCP §2030.220(a). Most often, this process is fairly straightforward. But there are at least three situations when responding to interrogatories may present a problem. Here’s how to skillfully handle them. Continue reading

Timing Your Requests for Admission

ThinkstockPhotos-487826116 (1)One of many tactical decisions you need to make in litigation is when to serve requests for admission. Timing may be key to getting what you need. Continue reading

Deposition Notice 101

ThinkstockPhotos-479864298In most cases you’ll need to notice at least one deposition. Here’s a handy overview for anyone new to California practice on what to include in your deposition notice and when to serve a subpoena along with it. Continue reading

Are Requests for Admissions a Magic Bullet or Overblown?

466464237Requests for admission are one of the best techniques to create admissible evidence for summary judgment and trial. Every litigator should understand the advantages of using them but also their limitations. Continue reading

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