Interrogatories - Trial Strategy Today

Sometimes Discovery Disputes Do Not Bring Out the Best in Us – Part II

E-Discovery LLC

JUNE 20, 2024

The main topic here is ‘contention interrogatories’…. Obviously, after years of government investigation and years of discovery, no one can say the contention interrogatories at issue here are premature.” The court explained that: “A large portion of the parties’ dispute has to do with what a contention interrogatory can ask for.

Discovery

Discovery Interrogatories Exhibits Litigation

CONSIDER A TRIAL CHECKLIST

Plaintiff Trial Lawyer Tips

OCTOBER 31, 2024

THREE PRIMARY DEFENSE CLAIMS __ __ __ PLAINTIFF PROOF OF CAUSATION __ DEFENDANT CAUSATION DEFENSE _ PRELIMINARY STATUS REVIEW  Review local rules regarding deadlines and requirements DISCOVERY REVIEW Interrogatories  Review defendant’s answers to interrogatories. Note incomplete answers for motion. Supplement if needed.

Cross-Examination

Cross-Examination Exhibits Interrogatories Opening Statement

“Boilerplate” Objections Are Generally Condemned; Except When They’re Not

E-Discovery LLC

OCTOBER 9, 2024

One example of the court sustaining a boilerplate objection follows: Walz Interrogatory No. Defendant Walz objected to this interrogatory as overbroad and in his response, argues that it attempts to sweep the entire case. 154-1 at 40. The Court agrees. As such, it is too broad.

Objections

Objections Discovery Interrogatories Admissibility

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StubHub: “The Court is not going to do that.”

E-Discovery LLC

AUGUST 16, 2024

The court rejected plaintiffs’ request for a query to “ to serve as the jumping off point for a collaborative, potentially iterative conversation with persons with technical knowledge of StubHub’s data, aimed at identifying those tables containing relevant information needed to adequately answer Plaintiffs’ Interrogatories.” emphasis added].

Interrogatories

Interrogatories Discovery Depositions Litigation

When is Failure to Provide a Timely Privilege Log Excusable?

E-Discovery LLC

JUNE 24, 2024

THE MELTON FACTORS In Melton , 2024 WL 3015749, at *5, the court recognized the general rule: “[A]s a general rule, when a party fails to object timely to interrogatories, production requests, or other discovery efforts, objections thereto are waived…. The court held that one interrogatory failed to request production of the bills.

Interrogatories

Interrogatories Objections Discovery Litigation

Another Cinderella Situation –Motion Denied as Untimely?

E-Discovery LLC

MAY 31, 2024

8, 2023); Court Uses an Informal Discovery Procedure to Hold That Untimely Objections Were Waived, and Answers to Interrogatories Defectively Referred to Deposition (Nov. Failure to Object to Untimely Interrogatories Coupled With a Discovery Violation Leads to Reversal (Jan. 1, 2023)( untimely discovery objection was waived); cf.

Interrogatories

Interrogatories Discovery Counterclaim Objections

E-Discovery 101 – – A Refresher on the Scope of Discovery + Boilerplate Objections Sustained

E-Discovery LLC

SEPTEMBER 16, 2024

“For example, in light of production of loan documents in response to Interrogatory No. Similarly, identification of details of transactions in response to Interrogatory No. 11 is unduly burdensome where the account statements have been produced.”

Discovery

Discovery Objections Interrogatories Pleadings

Requests for “Any and All” Documents Are Obsolete – Update

E-Discovery LLC

JULY 6, 2024

Judge Grimm, Chuck, and Paul suggested in “Maryland Discovery Problems”: “Limitation of the inquiry to ‘material’ and ‘principal’ facts, as opposed to ‘all’ facts makes the interrogatory acceptable in form.” In Maker’s Mark Distiller, Inc. Spalding Grp., 2021 WL 2018880 at *8 (W.D.

Interrogatories

Interrogatories Discovery Objections Litigation

Discovery From Former Attorney About Disputed Quid Pro Quo Offer to Opponent

E-Discovery LLC

OCTOBER 17, 2024

The court: set out the governing standard for discovery from an attorney and, denied a request to depose the attorney; but, authorized a limited interrogatory to him. The defendants, a Town and others , denied knowledge of the alleged offer. The plaintiffs wanted to develop certain property that they owned. emphasis added].

Discovery

Discovery Depositions Interrogatories Settlement Negotiations

TikTok’s ‘Grossly Insufficient’ Discovery Responses Lead to Motion to Compel in Cellspin Soft Patent Case

IP Watchdog

JUNE 10, 2024

On June 6, patent owner Cellspin Soft filed a motion to compel in the Eastern District of Texas seeking a court order requiring Chinese social media company TikTok to provide additional responses to interrogatories regarding proper venue in the case.

Interrogatories

Interrogatories Discovery Litigation

MyCase + Briefpoint: Save Hours Automating Discovery Requests

MyCase

MAY 7, 2024

Reclaim Hours Save up to three hours per discovery document with AI-generated responses to: Requests for production Requests for admission Interrogatories Notice of deposition Third-party subpoenas Form interrogatories 2.

Discovery

Discovery Interrogatories Subpoenas Admissibility

Do You Have to Ask an Opponent for a Privilege Log?

E-Discovery LLC

JUNE 25, 2024

at *5-6, passim , as well as contention interrogatories, id. See Accurate and Complete Discovery Responses Can Be Strategically Advantageous (May 13, 2024). The Norcold court addressed a number of other issues. [1] 1] __ [1] The court addressed boilerplate objections in detail, id. at *6, among other issues.

Discovery

Discovery Exhibits Interrogatories Objections

Relative Proportionality Argument Rejected

E-Discovery LLC

SEPTEMBER 25, 2024

The document requests and interrogatories at issue plainly seek information to which Plaintiffs are entitled, and Wiegand cannot seriously contend that the information is not relevant. For instance, Request No. sled at Wisp.”

Discovery

Discovery Objections Admissibility Expert Testimony

HOW TO PREPARE YOUR CLIENT FOR THEIR DEPOSITION by Lita Luvera

Plaintiff Trial Lawyer Tips

OCTOBER 17, 2024

You review interrogatory answers and any statements, and cover the issues in the case. SCHEDULE A MEET AND GREET IN THE CLIENTS HOME This meeting should be scheduled early in the case to learn the client’s story in greater detail and the focus should be on Damages not Liability. Cover the style of the defense lawyer if that is important.

Depositions

Depositions Interrogatories Witnesses Exhibits

Is a Vehicle’s “On Board” or “Dash Cam” Video Protected From Disclosure as “Work Product?”

E-Discovery LLC

OCTOBER 2, 2024

It also ruled on a motion to compel “better” responses to interrogatories and document requests. Compare E-Discovery 101 – – A Refresher on the Scope of Discovery + Boilerplate Objections Sustained (Sep. 16, 2024), with “Old” Sedona Paper Implements the “Specificity” Provision of Discovery Responses (Dec. 9, 2021). [2] 24, 2024).

Admissibility

Admissibility Discovery Objections Interrogatories

Felder: Part 1 of 4: Court-Ordered Transcription of “Meet and Confer” Session

E-Discovery LLC

AUGUST 13, 2024

The Court “presided over a discovery dispute hearing related to Plaintiff’s motions to compel interrogatory requests and requests for production of documents, and related to a motion for a protective order filed by the Defendant.” 7, 2024)(Simms, J.), plaintiff, acting pro se, sued her employer, alleging discrimination.

Discovery

Discovery Depositions Interrogatories Objections

11 ChatGPT Prompts to Transforming Your Legal Practice

Lawmatics

AUGUST 8, 2023

5 Developing Interrogatory Questions Prompt: "You're a personal injury attorney investigating a complex multi-vehicle accident. Draft focused interrogatory questions to unravel the chain of events and identify all parties involved and potentially responsible."

Legal Research

Legal Research Interrogatories Witnesses Legal Strategy

From Consultation to Judgment: What to Expect in a Personal Injury Claim

CaseFox

MARCH 23, 2023

This may include depositions, interrogatories, and requests for documents. Discovery: During the litigation process, both parties will engage in discovery, which involves exchanging information and evidence relevant to the case. Trial: If your case goes to trial, your attorney will present your case to a judge or jury.

Interrogatories

Interrogatories Depositions Evidence Discovery

The Law of Automobile Insurance in South Carolina: A Practitioner’s Guide

The Barrister

NOVEMBER 23, 2022

Some of these forms include sample affidavits, client letters, complaints, covenant not to execute, client intake sheets, requests for production, interrogatories, and subpoenas. It contains forty-two (42) sample forms on a CD. What is great about this resource is the sample forms are specifically tailored to insurance law.

Insurance

Insurance Interrogatories Affidavits Subpoenas

Scheduling Orders Are Mandatory; Vital to Caseload Management; and, Enforced Even Where Parties Got Themselves Into a “Pickle” by Dilatory Efforts to Cooperate

E-Discovery LLC

OCTOBER 10, 2024

The defendant did not answer the plaintiff’s interrogatories until mid-July…, and, after repeatedly failing to produce documents on promised dates, finally produced some documents in response to the plaintiff’s April requests in mid-August…. 30 at ¶ 7(a) (asking for a deadline several weeks from now to submit an ESI proposal).

Discovery

Discovery Mediation Depositions Interrogatories

Amendments to CR 26 and 30 Will Change Discovery and Deposition Practice

WA Bar News

NOVEMBER 12, 2024

That was always the rule if CR 33 (interrogatories) and CR 34 (requests for production) were read. Despite that, the Work Group found that some parties persisted in using general objections, claiming they were permissible because no rule expressly prohibited them.

Depositions

Depositions Discovery Objections Exhibits

Three Steps to Effective Delegation: What, Who and How

Attorney at Work

AUGUST 17, 2021

Examples: Drafting standard complaints and answers; routine answers to interrogatories or requests for admission; document review; performing more important project management tasks (creating and maintaining various tracking charts, client status update matrices, etc.); proofreading motions prior to filing.

Interrogatories

Interrogatories Defense Strategy Admissibility Litigation

Discovery is the Lawyer’s X-Ray; However, an MRI May Not Be Reasonable

E-Discovery LLC

SEPTEMBER 4, 2024

Mr. Subrin reports of a pre-1929 case in which 2,258 interrogatories were filed. Of course, while generally safe, they do expose a patient to radiation so there must be a justification for the procedure. However, sometimes an x-ray is not enough. Doctors may suggest an MRI when appropriate.

Discovery

Discovery Objections Evidence Litigation

Top 8 Legal AI Companies to Watch in 2024

MyCase

MAY 2, 2024

It leverages AI to suggest and write tailored content, such as Requests for Admission, Requests for Production, and Interrogatories. The platform automates repetitive aspects of drafting legal documents, particularly discovery documents, to expedite the process and improve efficiency.

Discovery

Discovery Case Management Litigation Interrogatories

LegalWeek 2024 Special Part Four: Joshua Lenon from Clio

3 Geeks and a Law Blog

FEBRUARY 22, 2024

Okay, so now I put it in the on answer to an interrogatory that I’m I’ve been drafting or now I put it in as part of a fact pattern in a pleading, or now I’m putting that in as proof of an alibi from a crime three years ago, right. Find that clients address from three years ago, right?

Technology

Technology Legal Services Interrogatories Pleadings

Trial Strategy Today

Sometimes Discovery Disputes Do Not Bring Out the Best in Us – Part II

CONSIDER A TRIAL CHECKLIST

Webinars

Trending Sources

“Boilerplate” Objections Are Generally Condemned; Except When They’re Not

Webinars

StubHub: “The Court is not going to do that.”

When is Failure to Provide a Timely Privilege Log Excusable?

Another Cinderella Situation –Motion Denied as Untimely?

E-Discovery 101 – – A Refresher on the Scope of Discovery + Boilerplate Objections Sustained

Requests for “Any and All” Documents Are Obsolete – Update

Discovery From Former Attorney About Disputed Quid Pro Quo Offer to Opponent

TikTok’s ‘Grossly Insufficient’ Discovery Responses Lead to Motion to Compel in Cellspin Soft Patent Case

MyCase + Briefpoint: Save Hours Automating Discovery Requests

Do You Have to Ask an Opponent for a Privilege Log?

Relative Proportionality Argument Rejected

HOW TO PREPARE YOUR CLIENT FOR THEIR DEPOSITION by Lita Luvera

Is a Vehicle’s “On Board” or “Dash Cam” Video Protected From Disclosure as “Work Product?”

Felder: Part 1 of 4: Court-Ordered Transcription of “Meet and Confer” Session

11 ChatGPT Prompts to Transforming Your Legal Practice

From Consultation to Judgment: What to Expect in a Personal Injury Claim

The Law of Automobile Insurance in South Carolina: A Practitioner’s Guide

Scheduling Orders Are Mandatory; Vital to Caseload Management; and, Enforced Even Where Parties Got Themselves Into a “Pickle” by Dilatory Efforts to Cooperate

Amendments to CR 26 and 30 Will Change Discovery and Deposition Practice

Three Steps to Effective Delegation: What, Who and How

Discovery is the Lawyer’s X-Ray; However, an MRI May Not Be Reasonable

Top 8 Legal AI Companies to Watch in 2024

LegalWeek 2024 Special Part Four: Joshua Lenon from Clio

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