Subject to and Without Waiving These Objections
I frequently receive responses to written discovery that feature a slew of objections, followed by some variant of “subject to
Read moreInterrogatories
Unverified Interrogatories are Still Useful
Rule 33 requires that interrogatory answers be verified. Unverified answers are considered non-responses. This does not mean, however, that unverified
Read moreThe Flaws of Reptilian Written Discovery
I have encountered some local opposing counsel who bought the book, attended the seminars, and are trying to use the
Read moreHow to Calculate Time for Purposes of Due Dates
How does a party know when the time allotted to complete a task has expired? Computing time is vital, such
Read moreObjections to Interrogatories: A Guide for New Lawyers
Among the more obnoxious errors that I encounter on a daily basis are objections to interrogatories. I discussed this twice
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