Tag Archives: Discovery Dispute

#1 Pretrial Agreements – Communication Technology

Discovery Disputes Will Be Resolved with a Phone Call Between Lead Counsel. One of the most counter-productive litigation activities is the discovery dispute letter.  Lawyers write these multi-page, single-spaced tomes not for the purpose of working out discovery disputes, but to create a record for an eventual motion to compel.  Such a letter typically generates a response in kind from opposing counsel, and then a reply, then a sur-reply.  In short, the parties draw battle lines instead of working toward an agreement. Counsel should not engage in discovery disputes for the purpose of engaging in discovery disputes.  Instead, counsel should …


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