Discovery (see also Depositions)

A proactive approach to the plaintiff’s deposition

Take advantage of the plaintiff’s deposition to showcase the humanity of your client – so the defense sees it, too

Getting past the roadblock of the commonly asserted design-immunity defense

From Issue: 2019 April

Inadvertent disclosure of privileged documents during discovery

Finding information cheaply about potential clients, defendants and witnesses

How the crafty defense lawyer hides things by avoiding the details in Requests for Production of Documents

You’ve served the subpoena duces tecum but still don’t have the documents – here’s your game plan

A look at RPDs, the most typical area of discovery disputes

From Issue: 2019 July

A guide to compelling their production over defendant’s objections

From Issue: 2018 April

How to analyze defendant’s motion in limine to exclude evidence not produced in discovery

Think you know it all? It’s not your grandmother’s Google

You must thoroughly research social media on every case and thoroughly brief your clients on how their postings may be used against them

From Issue: 2019 March

Care must be taken when presenting computer data in court to make sure alteration has not taken place through exposure to the Internet