Keep It Above the Belt
Litigation can be a nasty business. It is very easy to draw a theoretical line between personal and professional, however
Read moreDiscovery Motions
The Problem with “I Don’t Recall”
How many times have you heard that phrase during a deposition? How many times has it frustrated you? That phrase
Read moreThere is a Limit to the Scope of Discovery
I have recently been involved in a variety of cases where the opposing party served ever broader and broader discovery
Read moreEx Parte Orders Cannot Void a Deposition Notice
An ex parte order is one that a party obtains without notice to the opposing party. They are rare, in
Read moreMotions 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
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