Turn up the heat on your record subpoenas You’ve served the subpoena duces tecum but still don’t have the documents – here’s your game plan Clifton Smoot From Issue: 2018 December
The case of the runaway truck How demonstrative evidence was used to build the case against the MTA when its bus was struck by a runaway truck Geoff Wells From Issue: 2022 February
Sanctions – To ask or not to ask: That is the question The award of sanctions has often seemed arbitrary. Two recent decisions should help put the uncertainty to rest Andje MedinaJeremy Cloyd From Issue: 2012 June
Recovering attorney fees through requests for admissions Motions for cost-of-proof sanctions are challenging because section 2033.420 includes multiple hurdles and defenses Blair J. Berkley From Issue: 2021 August
Obtaining review of discovery rulings Commonly the only chance for correcting an erroneous discovery order is by writ of mandamus or prohibition From Issue: 2013 December
Motion to compel, or motion to compel further? How to determine whether a motion to compel discovery responses or a motion to compel further responses is the proper motion based on the circumstances Jake Cohen From Issue: 2018 April
The danger of exposure to the Internet Care must be taken when presenting computer data in court to make sure alteration has not taken place through exposure to the Internet Mike Cherry Edward J. Imwinkelried From Issue: 2008 January
Self-discovery Answering discovery helps one gain greater appreciation of the case Miles B. Cooper From Issue: 2017 October
Reporting for duty Track down all the incident reports, videos and maybe even a witness to better understand what happened Stephen Ellison From Issue: 2016 October
My first trial: Long discovery avoids surprises in the courtroom While it sometimes seems that discovery will never end, all of that information can add to your sense of preparedness for the trial Clare Capaccioli Velasquez From Issue: 2016 February
Metadata as blessing and burden The document speaks for itself (but does it say too much?) Miles B. Cooper From Issue: 2012 December
