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.
