4 Key Documents in a Motion to Compel

A motion to compel must consist of at least four documents. Here’s a handy checklist to be sure that you’ve got all your motion papers set to go. Continue reading

What to Tell Clients When Discovery Starts

starting discovery responsesOnce discovery starts, you’ll need to contact your client to help with responses. Here’s a sample letter to explain what is happening and what you need from your client. 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

Motion to Compel = Motion of Last Resort

One young man pull other oneThe other side is not giving you adequate discovery responses. In frustration, you may want to file a motion to compel. But stay calm and consider carefully whether doing so really makes sense and if there are better alternatives. Continue reading

Give Discovery Responses a Formal Introduction

136727429Many attorneys mistakenly believe that answers to interrogatories and requests for admission are automatically in evidence after they’re lodged with the court. Not so! First, you’ve got to formally introduce them into evidence.

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