Discovery

The “how to” for motions to compel

Motions to compel are powerful tools to educate opposing counsel on – and enforce – discovery obligations

Taylor R. Porter

From Issue: 2023 December

Show me what you got

Major California civil procedure changes with new mandatory disclosures (CCP § 2016.090)

Miles B. Cooper

From Issue: 2024 January

Protecting your client’s privacy in discovery

Be prepared to keep your client’s irrelevant personal history out of discovery whenever possible; that felony conviction, however, may be a bridge too far

Jeffrey Greenman

From Issue: 2018 March

Person-Most-Qualified depositions

Taking the PMQ deposition and using it effectively at trial

Alex Guerrero

From Issue: 2024 April

More thoughts about separate statements and motions to seal

Specific statements are required in many types of discovery disputes and in motions for summary adjudication

Randolph M. Hammock

From Issue: 2024 February

Maintaining deposition decorum

The role of discovery motions in a post-COVID-19 world; how to handle improper deposition objections

Steven M. Schuetze
Clare Lucich

From Issue: 2023 December

The added value of a private investigator in a motor-vehicle case

What you don’t learn from a police report may be just what you need to prove liability and identify other defendants

Harry Kazakian

From Issue: 2021 January

Securing the universe of documents in civil-rights actions

You are only as good a civil-rights practitioner as the discovery you compel. Yes, compel.

Denisse O. Gastélum

From Issue: 2021 February

Pre-litigation investigation strategies in single-plaintiff employment cases

Investigating your employment case after you retain the client but before filing a lawsuit will help ensure you avoid common litigation pitfalls and maximize case value

Joshua Cohen Slatkin

From Issue: 2023 March