Every Social Security Statement tells a story
April 25, 2015
The Social Security Statement, mailed annually or available for order online at http://www.socialsecurity.gov/forms/ssa-7050.pdf, is often the most valuable piece of financial information for alimony and
Discovery for defending domestic violence allegations in family court cases
March 19, 2015
Allegations of domestic violence in family court cases are often akin to shock grenades: intend to knock the other party back and on the defensive.
Remedies for the evasive deposition witness
September 18, 2014
Few areas of litigation practice are more frustrating than deposing an evasive, hostile or obnoxious witness. In the courtroom setting, a witness who acts these
Common Rule 11 violations in discovery requests and objections
April 3, 2014
I’m not sure my fellow members of the bar are aware they are doing it, but I see a whole lot of Rule 11 violations
The two types of motions to compel discovery
March 30, 2014
Although the rules of civil procedure don’t differentiate them, there are really two distinct types of motions to compel discovery: one addressing the untimeliness of
Should one verify what doesn’t have to be verified?
March 24, 2014
An old mentee of mine asked me if he should verify pleadings given that Rule 11(a) of the South Carolina Rules of Civil Procedure no
Two unusual, and quite useful, family law supplemental interrogatories
August 16, 2013
Though South Carolina family law attorneys are limited to fifty supplemental interrogatories, the boilerplate supplemental interrogatories I encounter are often ill designed to capture useful
Seeking protective orders for private investigator information
July 19, 2013
Since adultery is often a bar to alimony in South Carolina, family law attorneys here frequently employ private investigators (PIs). However, even when such PIs
