MJ Leen – Compelling Discovery

Motions to Compel Cannot Rely on Rule 26(a)(1) Alone

Occasionally I receive a motion to compel discovery that cites only Rule 26(a)(1), NRCP 16.1(a)(1) in state court. However, a

Last Thursday’s post gave an indication of where a motion to quash a subpoena should be filed. There is a

If my experience is typical, subpoenaing Metro for documentation is a royal pain. Often the response is an objection that

Several posts on this blog discuss the scope of requests for admission and examples of requests that exceed that scope.[1]

When an answer is filed it is typically accompanied by a varying of affirmative defenses. Then discovery opens and the