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Compelling Discovery

Civil discovery from beginning to end, with Michael Lowry

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Month: June 2012

Depositions Sanctions 

Deposition Baddies

June 13, 2012May 19, 2019 Michael Lowry Deposition Baddie, MJ Leen

You are in a deposition.  The defending attorney, and maybe others, are asserting what you believe are improper objections.  Asserting

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Interrogatories 

Counting Interrogatories

June 12, 2012May 19, 2019 Michael Lowry DC Bulla

You spent more time than you care to remember drafting 27 dynamite interrogatories and propounded them to your opponent sure

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Requests for Production Rule 35 Examinations 

Psychological Testing Data

June 11, 2012May 19, 2019 Michael Lowry

Case comes in.  The plaintiff has physical injuries but also asserts psychological injuries beyond “pain and suffering.”  The plaintiff is

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Early Case Conference 

Joint Case Conference Report & MSC

June 10, 2012May 19, 2019 Michael Lowry DC Bulla

In Nevada state courts, before discovery can open the parties are required to conduct what is called the “early case

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Interrogatories Requests for Production 

Better Written Discovery?

June 9, 2012May 19, 2019 Michael Lowry

Once the discovery period commences, I typically immediately send written discovery to begin gathering facts.  It is not unusual for

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