Requests for Production – Compelling Discovery

Assumes Facts Not in Evidence: A Valid Discovery Objection?

If an objection is worth making, make it a worthy objection. I still routinely receive responses that object that a

If a witness works for a corporate litigant, is that witness’ employment file discoverable? This issue was one of several

Clients often assume that by copying their lawyer on a communication, the communication becomes privileged. They’re wrong, and so are

This series has discussed limits in class action and ERISA litigation, this post discusses the crime/fraud exception generally. May you

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