Archive for March, 2018

The only two goals of responding to discovery

There are common bad practices of responding to discovery. One often sees responses that are incomplete and only partially respond to the request. The rules of civil procedure are quite explicit that an “incomplete answer is to be treated as a failure to answer.” Such incomplete responses subject the responder to a motion to compel, […]

Materials from preparing for family court temporary hearing lecture

The following is the outline for a presentation Elizabeth Stringer, Karen Fine, and I presented at the Charleston School of Law on January 12, 2018.  Links to word drafts of the materials follow. Temporary relief SCRFC 21 Substantive relief one is seeking at the conclusion of a case that is sought prior to trial Can […]


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