No one enjoys answering discovery—still don’t fight your attorney on responding to it

February 9, 2024

One of the least pleasant tasks in any litigation is responding to discovery. Little of what is produced in responding to discovery actually gets used

The danger of sandbagging witness lists and trial exhibits in discovery responses

November 11, 2023

The four standard interrogatories that are relevant to family court are basically questions about witnesses, expert witnesses, and trial exhibits.  Any initial request for production

Interrogatory answers need to be accurate, complete, and minimal

October 8, 2020

My standard procedure in answering interrogatories is to obtain an opposing party’s questions as a word document, cut and paste into my own responsive word

An evasive or incomplete answer is to be treated as a failure to answer

October 14, 2019

I find it curious that attorneys routinely treat incomplete or evasive discovery responses as no big deal. From my reading, Rule 37(a)(3), SCRCP, could not

The pitfalls of boilerplate supplemental interrogatories

September 14, 2019

I’m shocked how often I encounter supplemental interrogatories in family court in which the issuing attorney has clearly given no thought into how interrogatories might

The only two goals of responding to discovery

March 10, 2018

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

How automatic discovery has changed my family law practice

November 7, 2017

It’s been six months since the South Carolina Supreme Court mandated automatic discovery in family court. I didn’t expect this rule change to change my

Answering discovery you first object to

June 30, 2017

A pet peeve of mine is attorneys who begin discovery responses with a list of boilerplate objections. Recently I received interrogatory answers from two separate