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Local Rule Prohibiting Definitions in Interrogatories Without Leave of Court

E-Discovery LLC

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.

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Privilege Log Entry Was Relevant to Inquiry Notice Where Time-Bar Was at Issue

E-Discovery LLC

In Cáceres, privilege log entries appeared to show that plaintiffs were on notice of their claim months earlier than they asserted in interrogatory answers. The court also overruled an objection to the deposition of an SGR attorney. They sued for, inter alia , professional negligence in connection with tax advice. Emphasis added].

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Initial Disclosures Cannot Await Expert Opinions

E-Discovery LLC

Vasquez, Blake Lively’s Deposition Pushed Back by 2 Weeks After Judge’s Latest Ruling in Justin Baldoni Case (Jul. C]ourts in this district routinely find that a party may not refuse to respond to interrogatories seeking damages calculations on the ground that expert analysis will refine the damages calculation…. 14, 2025); I.

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Decision on How to Best Search for ESI – Court Orders ESI Protocol in “Epic of Dysfunctional Discovery,” With Unique Clawback Provision

E-Discovery LLC

22, 2023); Court Uses an Informal Discovery Procedure to Hold That Untimely Objections Were Waived, and Answers to Interrogatories Defectively Referred to Deposition (Nov. Procedures to Avoid, and Promptly Resolve, Discovery Disputes in the District of Maryland (Dec.

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Trellis Launches Trellis AI to Streamline Trial Court Litigation

Key Witnesses — Identify the people involved in the case and their roles to inform decisions about document requests, interrogatories, and depositions. Analyze Argument — Pinpoint the key arguments and evidence within opposing counsel's brief to help you draft a reply and prepare for a hearing. Want to learn more?

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When Can a Party Refer to Produced Records as an Answer to an Interrogatory?

E-Discovery LLC

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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HOW TO PREPARE YOUR CLIENT FOR THEIR DEPOSITION by Lita Luvera

Plaintiff Trial Lawyer Tips

“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.