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Most litigation and settlement outcomes are determined in quarrelsome discovery fights. Coercion and confrontation are usually necessary to obtain evidence on the hotly-contested issues.
To help you win more of these important discovery skirmishes, Ashley Lipson's Guerrilla Discovery offers dozens of clever strategies, novel arguments, direct answers, cautionary instructions, helpful timelines, tactically-annotated rules, and innovative forms that will help you handle even the most defiant deponents. In addition, Guerrilla Discovery:
• Offers answers and solid principles on how to propose and oppose virtually every form of evidence.
• Provides instant access to cases, statutes and checklists that will help you lay solid foundations, make accurate objections, and effectively examine.
• Divides the universe of evidence into four categories — testimonial, documentary, real and demonstrative — providing extreme detail in a concise, organized manner.
Table of Contents
Is It Discoverable?
Electronic, Digital and Other Media
Weapon Selection and Attack
Requests for Admissions
Notices for Production
Requests for Inspection
Physical and Mental Examinations
Defending and Responding in General
Defending Discovery's Limits
Using The Work Product Doctrine
Using Traditional Privileges
Exposing Burdensome and Abusive Tactics