Seeking procedural relief before seeking substantive temporary relief
February 23, 2013
My colleagues frequently recount war stories in which their attempts to obtain substantive relief on a temporary basis early in the case failed while subsequent
Objecting to discovery that you sought yourself
December 5, 2012
I often see attorneys object to discovery requests when those same attorneys request the same discovery. There are potential ethical violations and tactical problems in
The child custody interrogatory that often reveals more than it should
August 10, 2011
It’s typically hard to get useful information from child custody interrogatories. One question that often reveals more than it should is “Is there anything about
Stipulating to family court discovery
August 5, 2011
Unlike circuit court, there in no automatic discovery in South Carolina’s family court. See Rule 25, SCRFC. Most of the time, discovery is ordered at the
Disloyal collegiality in the prosecution and non prosecution of motions to compel
June 29, 2011
South Carolina attorneys are expected to be collegial. Part of that collegiality is a reluctance to file motions to compel discovery responses and a frequent
Verifying interrogatory answers
June 29, 2011
I prosecuted a motion to compel recently against an experienced attorney. One of the things I wanted his client compelled to do was verify the
“Shotgunning” motions to compel discovery
May 6, 2011
While the rules of civil procedure don’t create a distinction, there are really two types of motions to compel discovery. The first type of motion
Discovery in family court: shotgun or rifle approach?
January 15, 2011
Many of these blogs are inspired by young attorneys I am informally mentoring. This one was inspired by a query as to the sort of
