Requests for Production

When Will a Party’s Claims or Defenses Waive Privilege?

Last Thursday the Supreme Court of Nevada decided Wynn Resorts v. Okada, resolving two questions about how contentions during a

If a client hires a lawyer to defend a lawsuit and the complaint pleads causes of action with which the

Occasionally I encounter a case with a discovery schedule that stages discovery, often in more complex cases. “Fact” discovery will

I previously posted about why covert site inspections are generally a bad idea.[1] I even guessed as to what various

“It is time, once again, to issue a discovery wake-up call to the Bar in this District.” That is the