Discovery Problems and Their Solutions
This updated and expanded edition describes the problems that litigators encounter most frequently in pretrial discovery and presents suggestions and strategies for solving these problems. Following a discussion on the scope and types of discovery, discovery problems are presented as hypotheticals followed by a discussion that includes the law and helpful practice tips. Particular emphasis has been placed on the interpretation of the new rules, and evolving case law, concerning discovery of electronically stored information.
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2d Cir 5th Cir admission answer asserted attorney attorney-client privilege burden burdensome Civil Procedure claim client conference Corp costs court order covery defendant defendant's defense counsel depo deponent deposition disclose disclosure discovery plan discovery requests docu electronic discovery electronically stored information evidence examination expense facts failure Federal Rules fees filed a motion identify impeachment impose interrogatories issue lawyer LEXIS limited litigation litigation hold materials ment Meta-Data motion to compel N.D. Cal N.D. Ill notice objection opinion opposing party's person plaintiff plaintiff's counsel pretrial privilege log producing party protective order question reasonable relevant requesting party requests for production resolve responding party response Rule 34 Rules of Civil sanctions scope served specific spoliation of evidence Standard stipulation subdivision subpoena substantial Supp supra testify testimony tion trial U.S. Dist U.S. District Court United unless waived waiver work-product doctrine