
Stop Defense Obstruction: Dealing with Written Discovery and Protective Order Abuse - On Demand
Written discovery is critical. You need it to properly prepare for depositions, create or respond to motions, and arm or cross-examine experts. Yet reasonable discovery requests are often defeated by the defense’s obstructive tactics. Join Morgan Adams for a 60-minute program to learn how to deal with below-standard (BS) discovery objections and protective orders in federal and state court. In this program, Mr. Adams will cover: Updated FRCP on discovery: the new “proportionality” test and the death of “not reasonably calculated to lead to the discovery of admissible evidence” Proper sequencing of discovery Improper discovery: omnibus terms in discovery such as “any and all facts” Boilerplate objections, reservations of rights, and general and preliminary objections Making proper objections and avoiding sanctions as a plaintiff (if you have not changed your standard objections since 2015, you may be subject to sanctions) Dealing with the typical defense runaround: Interrogatories Re