Focus (Forum & Focus)
Sep. 7, 2007
Compliance with Production Requests is Harder Than it Looks
Forum Column - By Richard M. Coleman - The "Musings of a Discovery Referee" series continues with a look at some of the common mistakes that result from reading statutes without adequate care.
By Richard M. Coleman
Here are three instances in which respondents asserted they complied with the requested production. Did they?
1. After stating objections in general terms, the respondent concluded with the following language: "Without waiving these objections and subject to them, and specifically excluding any communications between attorney and client, defendant respo...
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