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Author: Michael Lowry

Requests for Production 

Limits on the Attorney-Client Privilege: ERISA

March 9, 2020February 10, 2020 Michael Lowry Attorney-Client Privilege, MJ Ferenbach

The first post in this series discussed the limits of the attorney-client privilege in the context of attorney-fee agreements with

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Requests for Production 

Limits on the Attorney-Client Privilege: Discovering Fee Agreements

March 2, 2020February 10, 2020 Michael Lowry Attorney-Client Privilege, MJ Leen

The attorney-client privilege doesn’t protect as much as many think it does.  Knowing where the line might be in a

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Depositions 

Irrelevant is not a Deposition Objection

February 24, 2020February 11, 2020 Michael Lowry

Deposition objections are an area prone to abuse but also often misunderstood.[1]  Those combinations sometimes can cost deponents and their

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Requests for Production 

Civil Discovery v. Grand Juries

February 18, 2020March 18, 2020 Michael Lowry

It might be wonderful to learn the opposing party was subject to an investigation that resulted in criminal grand jury

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Requests for Admission 

Go Ahead, Waste Your Requests for Admission

February 10, 2020February 2, 2020 Michael Lowry DC Ayres

Requests for admission remain one of the most misunderstood aspects of discovery.  They frustrate me on a regular basis and

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