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.
“I don’t know/recall” may be the best interrogatory or deposition answer you can get
April 21, 2016
I lectured last week to recent law school graduates about family law discovery. Part of this lecture discussed Rule 37(a)(3), SCRCP which reads: “Evasive or
Using opposing parties’ evasive discovery responses against them
February 9, 2016
Often opposing parties will respond to discovery with evasion: giving answers that respond to some, slightly different allegation; providing lengthy responses to “yes/no” questions without
