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

Automatic discovery in family court–finally

May 1, 2017

Effective today (May 1, 2017) the South Carolina Supreme Court has amended Rule 25, SCFCR, to authorize automatic discovery in family court. In 23 years

Best practices in responding to requests for production

February 17, 2017

I spend a lot of time struggling to get opposing attorneys to fully respond to requests for production. Often it’s hard to tell if the

Obtaining electronically stored information in electronically stored format

July 21, 2016

A common idea among litigators is that an excellent way to hide damaging information is to produce it with a whole bunch of innocuous information.

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