How to Make Clear, Quick and Effective Objections
Podcast - A Checklist of Common Objections
It’s a common practice during a deposition for lawyers to assert legal objections to witness testimony but then allow the deposition to proceed. In fact, this practice is broadly encouraged. Depositions are wide-ranging...more
Interrogatories can serve as a useful tool for parties to obtain basic information about their adversary’s case and drive discovery strategy. Serving interrogatories allows parties to identify individuals with knowledge and...more
In In re GreCon, Inc., a Texas appellate court recently addressed when a party must produce settlement agreements. The plaintiff sued multiple defendants in tort after a fire, and settled with all except GreCon. After...more
The rules governing how litigants conduct written discovery changed substantially on December 1, 2015, when major amendments to the Federal Rules of Civil Procedure took effect....more
The Eastern District of Texas recently criticized a party's statement in its written discovery responses that it would produce documents "subject to" its objections. See Realpage, Inc. v. Enterprise Risk Control, LLC, No....more
May you preserve an objection to personal jurisdiction by including a general denial to the complaint’s allegation in your answer and then moving to dismiss on personal jurisdiction grounds less than three (3) months later?...more
A growing number of federal courts have confirmed that the once-common discovery practice of asserting an objection followed by a bare "conditional" response, i.e., stating that "Subject to and without waiving the stated...more