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Compelling Discovery

Civil discovery from beginning to end, with Michael Lowry

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MJ Hoffman

Subpoenas 

Can a Subpoena be Served via Substitute Service?

February 19, 2015March 14, 2015 Michael Lowry MJ Hoffman

Assume you want to depose a non-party but the non-party is represented by counsel and will not appear voluntarily. You

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Rule 35 Examinations 

Play Nice with Rule 35 Examinations

February 2, 2015March 14, 2015 Michael Lowry MJ Hoffman

Changing discovery strategy in the middle of a case can create problems. Refusing or entirely failing to do what you

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Depositions Discovery Motions Sanctions 

Giving Thanks by Omission

November 26, 2014November 25, 2014 Michael Lowry MJ Ferenbach, MJ Hoffman

Many people this time of year give thanks for something that has happened in their lives. In typical lawyer fashion,

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Depositions Discovery Motions 

Need More Than 7 Hours for a Deposition?

November 20, 2014November 24, 2014 Michael Lowry MJ Hoffman

If 1 day of 7 hours is not enough to complete your deposition, what do you do? File a motion.

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Requests for Production 

What is an Overbroad Request for Production?

November 3, 2014November 24, 2014 Michael Lowry MJ Hoffman

Among the standard, often improper, objections I receive to requests for production is the request is overbroad. When is a

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