Depositions Evidence Interrogatories 
E-Discovery LLC
JULY 31, 2025
The court cited a local rule that prohibits use of definitions in interrogatories without leave of court. In pertinent part, Herman objected to the definitions in Payne’s interrogatories. b) (“A party may not separately define words used in an interrogatory without the court’s leave.”). applies only to interrogatories.
E-Discovery LLC
JANUARY 8, 2025
Plaintiff contended that, in response to plaintiffs interrogatories, Defendants improperly refer to hundreds of pages of documents, which is non-responsive, evasive, and in violation of Federal Rule of Civil Procedure 33(d). First, it must show that a review of the documents will actually reveal answers to the interrogatories.
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Plaintiff Trial Lawyer Tips
OCTOBER 17, 2024
“By failing to prepare, you are preparing to fail” Benjamin Franklin In our office, my law partner and wife, Lita Barnett Luvera, legal responsibilities included preparing clients and witness for their deposition. Too often, lawyers tend to schedule an hour or two in their office on the day of the deposition to prepare their client.
E-Discovery LLC
AUGUST 16, 2024
The court rejected plaintiffs’ request for a query to “ to serve as the jumping off point for a collaborative, potentially iterative conversation with persons with technical knowledge of StubHub’s data, aimed at identifying those tables containing relevant information needed to adequately answer Plaintiffs’ Interrogatories.” emphasis added].
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Analyze Argument — Pinpoint the key arguments and evidence within opposing counsel's brief to help you draft a reply and prepare for a hearing. Key Witnesses — Identify the people involved in the case and their roles to inform decisions about document requests, interrogatories, and depositions.
Plaintiff Trial Lawyer Tips
OCTOBER 31, 2024
THREE PRIMARY DEFENSE CLAIMS __ __ __ PLAINTIFF PROOF OF CAUSATION __ DEFENDANT CAUSATION DEFENSE _ PRELIMINARY STATUS REVIEW Review local rules regarding deadlines and requirements DISCOVERY REVIEW Interrogatories Review defendant’s answers to interrogatories. Note incomplete answers for motion. Supplement if needed.
E-Discovery LLC
OCTOBER 17, 2024
The court: set out the governing standard for discovery from an attorney and, denied a request to depose the attorney; but, authorized a limited interrogatory to him. They also sought the former attorney’s deposition regarding the alleged offer. Thus, those two factors weighed in favor of a deposition.
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