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CONSIDER A TRIAL CHECKLIST

Plaintiff Trial Lawyer Tips

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.

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Court Recommends Denial of Rule 37(e)(2) Motion, While Providing Guidance Under Rule 37(e)(1)

E-Discovery LLC

Self Help Discovery Results in Striking of Wrongfully Obtained Evidence (Mar. The Court wrote that: Eventually, the parties both filed discovery motions seeking access to Plaintiff’s now-located cell phone, with the Court ordering a forensic examination of the phone, the SIM card, and Plaintiff’s iCloud account.

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