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MJ Leen

Affirmative Production of Witnesses & Documents Discovery Motions 

Motions to Compel Cannot Rely on Rule 26(a)(1) Alone

June 15, 2017June 29, 2019 Michael Lowry MJ Leen

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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Subpoenas 

Subpoena-thon: Transferring a Motion to Quash a Subpoena

December 5, 2016July 2, 2019 Michael Lowry MJ Koppe, MJ Leen, Subpoena-thon

Last Thursday’s post gave an indication of where a motion to quash a subpoena should be filed.  There is a

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Subpoenas 

Debunking Metro’s Reliance on the Deliberative Process Privilege

September 26, 2016September 5, 2016 Michael Lowry MJ Koppe, MJ Leavitt, MJ Leen

If my experience is typical, subpoenaing Metro for documentation is a royal pain.  Often the response is an objection that

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Requests for Admission 

Wasted Requests for Admission

August 18, 2016August 13, 2016 Michael Lowry MJ Leen

Several posts on this blog discuss the scope of requests for admission and examples of requests that exceed that scope.[1] 

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Depositions Interrogatories Requests for Production 

What Discovery is Permitted for Affirmative Defenses?

May 2, 2016January 4, 2016 Michael Lowry MJ Leen

When an answer is filed it is typically accompanied by a varying of affirmative defenses. Then discovery opens and the

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