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Litigation Strategies Document Productions Summary Judgment

McGuireWoods LLP

How Does Work Product Protection Apply to Lawyers’ Witness Interview Notes? Two Courts Disagree on the Same Day: Part I

McGuireWoods LLP on

Litigators frequently interview fact witnesses in pending or anticipated litigation settings. Their interview notes normally deserve fact work product protection, but that can be overcome if the witnesses disappear or their...more

Farrell Fritz, P.C.

The Proof Is in the Note: Commercial Division Holds a Heter Iska is Not Outside Proof for Purposes of Summary Judgment in Lieu of...

Farrell Fritz, P.C. on

As many practitioners are aware, the litigation process in New York often feels like a tortoise race, with many cases taking years to resolve. Section 3213 of the CPLR (“Summary Judgment in Lieu of Complaint”) is a bit of an...more

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