PRETRIAL LITIGATION IN A NUTSHELL. R. LAWRENCE DESSEM Professor of Law University of Tennessee ST. PAUL, MINN. WEST PUBLISHING CO.

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "PRETRIAL LITIGATION IN A NUTSHELL. R. LAWRENCE DESSEM Professor of Law University of Tennessee ST. PAUL, MINN. WEST PUBLISHING CO."

Transcription

1 PRETRIAL LITIGATION IN A NUTSHELL By R. LAWRENCE DESSEM Professor of Law University of Tennessee ST. PAUL, MINN. WEST PUBLISHING CO. 1992

2 PREFACE AND ACKNOWLEDGMENTS.. TABLE OF CASES TABLE OF STATUTES AND RULES v xv xvn Chapter One. Introduction 1 I. An Overview of Pretrial Litigation 1 II. The Law Governing Pretrial Litigation 3 III. The Lawyer's Role in Pretrial Litigation 9 Chapter Two. Client Interviewing and the Establishment of the Attorney-Client Relationship - 11 I. The Importance of Client Interviewing 11 II. The Structure of the Initial Attorney- Client Interview 13 A. Introductions and Introductory Remarks 14 B. The Client's Problem Definition.. 16 C. The Client's Narrative.. 17 D. The Relief Sought by the Client.. 18 E. Attorney Follow-Up Questioning 19 F. Concluding Remarks 22 III. Interviewing Techniques 23 A. Traditional Techniques to Facilitate Communication 24 IX

3 III. Interviewing Techniques Continued B. Active Listening 29 IV. The Client's Retainer of the Attorney 31 Chapter Three. Pretrial Planning and Investigation 35 I. The Need to Plan Litigation 35 II. Preparing the Litigation Plan 38 III. Legal Research 43 A. Legal Research During the Pretrial Process 44 B. The Litigation Grid 47 IV. Factual Investigation 50 A. Investigative Structure and Strategy 51 B. Investigative Techniques Witness Interviews Witness Statements 64 Chapter Four. The Complaint 68 I. Prerequisites to Suit 68 II. The Claims Asserted 75 III. The Relief Requested 78 IV. Modern Pleading and Practice 85 V. Rule 11 Pleading Requirements 93 VI. Amendment of the Pleadings 96 Chapter Five. Responses to the Complaint 100 I. Defenses to the Action 100 II. Consolidation and Waiver of Defenses 102 III. Rule 12 Motions 104 A. The Motion to Dismiss 106 X

4 III. Rule 12 Motions Continued B. The Other Rule 12 Motions Ill IV. The Answer 115 V. Counterclaims, Cross-Claims, and Third-Party Claims 121 A. Counterclaims 121 B. Cross-Claims 125 C. Third-Party Claims 127 Chapter Six. The Scope of Civil Discovery 131 I. The General Scope of Discovery Under Rule A. Relevance 134 B. Privilege 137 II. The Work-Product Doctrine 139 III. Discovery Concerning Experts 144 IV. Discovery Conferences, Orders, and Planning 149 V. Discovery Supplementation and Certification 153 Chapter Seven. Interrogatories 157 I. The Rule 33 Interrogatory 157 II. Using and Drafting Interrogatories III. Responding to Interrogatories 172 Chapter Eight. Depositions 179 I. Depositions under the Federal Rules of Civil Procedure 179 II. The Decision to Take a Deposition 186 III. Preparing to Take a Deposition 190 XI

5 IV. The Taking of Deposition Testimony V. Deposition Questioning Techniques VI. Expert Depositions 202 VII. Preparing Witnesses for their Depositions 204 VIII. Defending Depositions 211 Chapter Nine. Requests for Production, Examinations, and Admissions 218 I. Rule 34 Requests to Produce. 218 II. Rule 35 Examinations III. Rule 36 Admission Requests 228 Chapter Ten. Judicial Intervention Into the Discovery Process. 237 I. Discovery Disputes 237 II. Rule 26(c) Motions for Protective Orders 241 III. Rule 37 Motions to Compel 246 IV. Rule 37 Motions for Discovery Sanctions 249 Chapter Eleven. Pretrial Motion Practice 258 I. Pretrial Motions A. Motions Based Upon a Party's Failure to Properly Contest a Lawsuit 259 B. Motions for a Change of Forum C. Motions Affecting the Timing of the Action 268 XII

6 I. Pretrial Motions Continued D. Motions Affecting the Trial of the Action 269 E. Other Miscellaneous Motions 270 II. Pretrial Motion Strategy 271 III. The Written Motion Papers 275 IV. Motion Argument 283 Chapter Twelve. Summary Judgment 292 I. Rule 56 Summary Judgment Procedure 292 II. Effective Use of Summary Judgment Motions 297 III. Defending Against Motions for Summary Judgment 307 Chapter Thirteen. Pretrial Conferences and Pretrial Orders 315 I. Pretrial Conferences 315 II. Preparation for, and Handling of, Pretrial Conferences 319 III. Pretrial Orders 323 IV. Judicial Involvement in the Pretrial Process 333 Chapter Fourteen. Negotiation and Settlement 337 I. Pretrial Settlement Negotiations 337 A. Evaluating a Case for Settlement 338 B. Negotiating the Settlement 343 C. Negotiation Tactics and Techniques 349 Xffl

7 II. Third-Party Settlement Facilitation m. Negotiation Ethics 361 IV. Memorializing the Settlement 365 INDEX 371 XIV

SUPERIOR COURT OF NEW JERSEY LAW DIVISION: MIDDLESEX COUNTY DOCKET NO. L- IN RE: MIDDLESEX ASBESTOS LITIGATION CIVIL ACTION ASBESTOS LITIGATION

SUPERIOR COURT OF NEW JERSEY LAW DIVISION: MIDDLESEX COUNTY DOCKET NO. L- IN RE: MIDDLESEX ASBESTOS LITIGATION CIVIL ACTION ASBESTOS LITIGATION SUPERIOR COURT OF NEW JERSEY LAW DIVISION: MIDDLESEX COUNTY DOCKET NO. L- IN RE: MIDDLESEX ASBESTOS LITIGATION CIVIL ACTION ASBESTOS LITIGATION GENERAL ORDER I. COMPLAINTS A. All complaints must: 1. Include

More information

FINAL JOINT PRETRIAL ORDER. This matter is before the Court on a Final Pretrial Conference pursuant to R. 4:25-1.

FINAL JOINT PRETRIAL ORDER. This matter is before the Court on a Final Pretrial Conference pursuant to R. 4:25-1. SUPERIOR COURT OF NEW JERSEY MIDDLESEX COUNTY:LAW DIVISION Docket No. Plaintiff(s), v. Defendant(s). FINAL JOINT PRETRIAL ORDER This matter is before the Court on a Final Pretrial Conference pursuant to

More information

DEFENSE RESEARCH INSTITUTE RECOMMENDED CASE HANDLING GUIDELINES FOR INSURERS

DEFENSE RESEARCH INSTITUTE RECOMMENDED CASE HANDLING GUIDELINES FOR INSURERS DEFENSE RESEARCH INSTITUTE RECOMMENDED CASE HANDLING GUIDELINES FOR INSURERS I. PREFACE Philosophy [Insurer] expects to work with the Firm and the insured to achieve the best result for the insured in

More information

Case4:12-cv-03288-KAW Document2-1 Filed06/25/12 Page1 of 7 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION

Case4:12-cv-03288-KAW Document2-1 Filed06/25/12 Page1 of 7 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION Case4:12-cv-03288-KAW Document2-1 Filed06/25/12 Page1 of 7 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION STANDING ORDER FOR MAGISTRATE JUDGE KANDIS A. WESTMORE (Revised

More information

2 California Evidence (5th), Discovery

2 California Evidence (5th), Discovery 2 California Evidence (5th), Discovery I. GENERAL PRINCIPLES A. [ 1] Purpose of Discovery. B. [ 2] Modern Discovery Procedures. C. [ 3] Relation to Pretrial Conference. D. Overview of California Discovery

More information

Supreme Court Rule 201. General Discovery Provisions. (a) Discovery Methods.

Supreme Court Rule 201. General Discovery Provisions. (a) Discovery Methods. Supreme Court Rule 201. General Discovery Provisions (a) Discovery Methods. Information is obtainable as provided in these rules through any of the following discovery methods: depositions upon oral examination

More information

ATTORNEY HELP CENTER: MEDICAL MALPRACTICE

ATTORNEY HELP CENTER: MEDICAL MALPRACTICE ATTORNEY HELP CENTER: MEDICAL MALPRACTICE The healthcare industry has exploded over the last thirty years. Combined with an increasing elderly population, thanks to the Baby Boomer generation, the general

More information

IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA.

IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA. IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA. CASE NO.: 16- DIVISION: CV- vs. Plaintiff, Defendant. ORDER SETTING CASE FOR JURY TRIAL AND PRETRIAL CONFERENCE AND REQUIRING

More information

PART III Discovery. Overview of the Discovery Process CHAPTER 8 KEY POINTS THE NATURE OF DISCOVERY. Information is obtainable by one or more discovery

PART III Discovery. Overview of the Discovery Process CHAPTER 8 KEY POINTS THE NATURE OF DISCOVERY. Information is obtainable by one or more discovery PART III Discovery CHAPTER 8 Overview of the Discovery Process Generally, discovery is conducted freely by the parties without court intervention. Disclosure can be obtained through depositions, interrogatories,

More information

Acknowledgments Introduction: Welcome to the Labyrinth. CHAPTER 1 Gathering the Evidence 1. CHAPTER 2 Third-Party Experts 25

Acknowledgments Introduction: Welcome to the Labyrinth. CHAPTER 1 Gathering the Evidence 1. CHAPTER 2 Third-Party Experts 25 Acknowledgments Introduction: Welcome to the Labyrinth xi xiii CHAPTER 1 Gathering the Evidence 1 Form 1.1: General Preliminary Electronic Evidence Questions for Your Client 3 Form 1.2: Checklist to Define

More information

RARITAN VALLEY COMMUNITY COLLEGE ACADEMIC COURSE OUTLINE FAMILY LAW LEGL-124

RARITAN VALLEY COMMUNITY COLLEGE ACADEMIC COURSE OUTLINE FAMILY LAW LEGL-124 1 RARITAN VALLEY COMMUNITY COLLEGE ACADEMIC COURSE OUTLINE FAMILY LAW LEGL-124 I. Basic Course Information A. Course Title and Number: Family Law LEGL-124 B. New or Modified Course: Modified C. Date of

More information

Initial Considerations in Defending a Lawsuit

Initial Considerations in Defending a Lawsuit Chapter 8 Initial Considerations in Defending a Lawsuit By M. Warren Butler and Alex Terry Wood Y ou ve just survived three years in law school and the Bar Exam, and it is your first day as a new associate

More information

IN THE SUPREME COURT OF THE STATE OF ALASKA ORDER NO. 1682. Pretrial Conferences; Scheduling; Management.

IN THE SUPREME COURT OF THE STATE OF ALASKA ORDER NO. 1682. Pretrial Conferences; Scheduling; Management. IN THE SUPREME COURT OF THE STATE OF ALASKA ORDER NO. 1682 Amending Civil Rules 16, 26, 33, 34, 37, and 45 concerning Discovery of Electronic Information IT IS ORDERED: 1. Civil Rule 16 is amended to read

More information

CIVIL PROCEDURE 101. Presentation by: Judge Emily Peacock, Scott Silverman, Esq. and Loren Beer, Esq.

CIVIL PROCEDURE 101. Presentation by: Judge Emily Peacock, Scott Silverman, Esq. and Loren Beer, Esq. CIVIL PROCEDURE 101 Presentation by: Judge Emily Peacock, Scott Silverman, Esq. and Loren Beer, Esq. The Federal Rules govern the conduct of all civil actions brought in Federal district courts. The Florida

More information

RARITAN VALLEY COMMUNITY COLLEGE ACADEMIC COURSE OUTLINE ROLE OF THE PARALEGAL LEGL-101

RARITAN VALLEY COMMUNITY COLLEGE ACADEMIC COURSE OUTLINE ROLE OF THE PARALEGAL LEGL-101 1 RARITAN VALLEY COMMUNITY COLLEGE ACADEMIC COURSE OUTLINE ROLE OF THE PARALEGAL LEGL-101 I. Basic Course Information A. Course Title and Number: Role of the Paralegal LEGL-101 B. New or Modified Course:

More information

What to Expect In Your Lawsuit

What to Expect In Your Lawsuit What to Expect In Your Lawsuit A lawsuit is a marathon not a sprint. Stewart R. Albertson. There is a saying that the wheels of justice move slowly. That is as true today as when it was initially stated.

More information

ALL OF THE BELOW DUTIES ARE ASSUMED TO, AND MUST BE, UNDER THE DIRECTION AND SUPERVISION OF A LICENSED ATTORNEY.

ALL OF THE BELOW DUTIES ARE ASSUMED TO, AND MUST BE, UNDER THE DIRECTION AND SUPERVISION OF A LICENSED ATTORNEY. CIVIL LITIGATION PARALEGAL 2007 revision and update by Barbara Biondolillo of Berenbaum, Weinshienk & Eason, P.C., and Peggy Upton, formerly of the same firm. 2007 Revision and update reviewed by Larry,

More information

Discovery Devices. Rule 26 requires the automatic disclosure of a host of basic information regarding the case

Discovery Devices. Rule 26 requires the automatic disclosure of a host of basic information regarding the case Discovery Devices Automatic (mandatory) disclosure Rule 26 requires the automatic disclosure of a host of basic information regarding the case Interrogatories Questions addressed to the other party Depositions

More information

Computing and Extending Time; Time. The following rules apply in

Computing and Extending Time; Time. The following rules apply in AMENDMENTS TO THE FEDERAL RULES OF CIVIL PROCEDURE Rule 6. Computing and Extending Time; Time for Motion Papers (a) Computing Time. The following rules apply in computing any time period specified in these

More information

CLASS TIMES: Tuesday and Friday: 10:45am to 12:15pm

CLASS TIMES: Tuesday and Friday: 10:45am to 12:15pm SOUTHWESTERN LAW SCHOOL CIVIL PROCEDURE II PROFESSOR DENNIS YOKOYAMA Syllabus, Course Requirements, and Grading Criteria SPRING 2011 CLASS TIMES: Tuesday and Friday: 10:45am to 12:15pm OFFICE HOURS: My

More information

CIVIL MOTION PANEL STATEMENT OF CONSENSUS. Current As of November 2, 2004 (Authorities Updated 02/2007)

CIVIL MOTION PANEL STATEMENT OF CONSENSUS. Current As of November 2, 2004 (Authorities Updated 02/2007) CIVIL MOTION PANEL STATEMENT OF CONSENSUS Current As of November 2, 2004 (Authorities Updated 02/2007) The Civil Motions Panel of the Circuit Court is a voluntary group of judges who agree to take on the

More information

Rule 26. General Provisions Governing Discovery.

Rule 26. General Provisions Governing Discovery. Published on Arkansas Judiciary (https://courts.arkansas.gov) Rule 26. General Provisions Governing Discovery. (a) Discovery Methods. Parties may obtain discovery by one or more of the following methods:

More information

COMMONWEALTH OF MASSACHUSETTS THE TRIAL COURT STANDING ORDER NO. 2-86 (AMENDED)

COMMONWEALTH OF MASSACHUSETTS THE TRIAL COURT STANDING ORDER NO. 2-86 (AMENDED) COMMONWEALTH OF MASSACHUSETTS THE TRIAL COURT SUFFOLK, ss. SUPERIOR COURT DEPARTMENT STANDING ORDER NO. 2-86 (AMENDED) Applicable to All Counties to cases initiated by indictment on or after September

More information

California Points and Authorities

California Points and Authorities California Points and Authorities Publisher: Matthew Bender Elite Products Table of Contents Volume 1 Chapter 1 Writing Legal Memoranda and Briefs Chapter 10 Abatement And Survival of Actions Chapter 11

More information

What to Expect When You re Expecting A Lawsuit

What to Expect When You re Expecting A Lawsuit What to Expect When You re Expecting A Lawsuit Jennifer G. Hall Meadowbrook Office Park 4268 I-55 North Jackson, MS 39211 601.351.2483 jhall@bakerdonelson.com What can Trigger a Lawsuit? Anything and everything

More information

Civil Suits: The Process

Civil Suits: The Process Jurisdictional Limits The justice courts have exclusive jurisdiction or the authority to hear all civil actions when the amount involved, exclusive of interest, costs and awarded attorney fees when authorized

More information

CALIFORNIA TORT FORMS FROM EXPERT LITIGATORS (1st Edition) July 2015 TABLE OF CONTENTS

CALIFORNIA TORT FORMS FROM EXPERT LITIGATORS (1st Edition) July 2015 TABLE OF CONTENTS CALIFORNIA TORT FORMS FROM EXPERT LITIGATORS (1st Edition) July 2015 TABLE OF CONTENTS File Name Book Section Title CH01 Chapter 1 Animals 01-006 1.6 Sample Client Authorization to Release Medical 01-007

More information

PRE-TRIAL ADVOCACY Law 521 FALL 2015 Professor Jason R. Caraway

PRE-TRIAL ADVOCACY Law 521 FALL 2015 Professor Jason R. Caraway I. Class Time & Room Room 108 Wednesdays 6:00-8:15 PRE-TRIAL ADVOCACY Law 521 FALL 2015 Professor Jason R. Caraway COURSE SYLLABUS II. Contact Information Prof. Jason R. Caraway SIU LAW/Kolker Law Offices,

More information

Justice Court Rules of Civil Procedure: Table of Contents

Justice Court Rules of Civil Procedure: Table of Contents Justice Court Rules of Civil Procedure: Table of Contents Part I: General provisions. Rule 101: Application and interpretation. Rule 102: Duties of a party. Rule 103: Conducting a lawsuit. Part II: The

More information

6 First-Party Litigation

6 First-Party Litigation I. Overview 6.1 6 First-Party Litigation II. Initial Client Meeting A. In General 6.2 B. Identifying the Proper Insurer 6.3 C. Determining the Types of Benefits Recoverable 1. In General 6.4 2. Work Loss

More information

Personal Injury Litigation

Personal Injury Litigation Personal Injury Litigation The Anatomy of a New York Personal Injury Lawsuit An ebook by Stuart DiMartini, Esq. 1325 Sixth Avenue, 27 th Floor New York, NY 10019 212-5181532 dimartinilaw.com Introduction

More information

TITLE I REDUCTION OF ABUSIVE LITIGATION

TITLE I REDUCTION OF ABUSIVE LITIGATION 109 STAT. 737 Public Law 104 67 104th Congress An Act To reform Federal securities litigation, and for other purposes. Be it enacted by the Senate and House of Representatives of the United States of America

More information

QUESTIONS & ANSWERS: CIVIL PROCEDURE

QUESTIONS & ANSWERS: CIVIL PROCEDURE QUESTIONS & ANSWERS: CIVIL PROCEDURE LexisNexis Law School Publishing Advisory Board Bridgette Carr Clinical Professor of Law University of Michigan Law School Steven I. Friedland Professor of Law and

More information

NOTICE TO THE ASBESTOS BAR

NOTICE TO THE ASBESTOS BAR NOTICE TO THE ASBESTOS BAR Please be advised that the Case Management Order for Asbestos-Related Personal Injury Claims and the Asbestos Summary Judgment Motion Procedures have been revised, effective

More information

Litigating the Non-Intervened Case

Litigating the Non-Intervened Case I. SCREENING CASES Litigating the Non-Intervened Case Statistically the Government intervenes in only 21.6% of all qui tam cases filed. i Included within that percentage are cases where the Government

More information

Exercise Five - Motions to Dismiss and Waiver Under Federal Rule 12. Roger C. Park and Douglas D. McFarland

Exercise Five - Motions to Dismiss and Waiver Under Federal Rule 12. Roger C. Park and Douglas D. McFarland Exercise Five - Motions to Dismiss and Waiver Under Federal Rule 12 Roger C. Park and Douglas D. McFarland December 29, 2010 2 Contents 1 Raising, and Waiving, Rule 12 Defenses 5 1.1 The Federal Rule 12(b)

More information

Rule 26. General provisions governing discovery.

Rule 26. General provisions governing discovery. Article 5. Depositions and Discovery. Rule 26. General provisions governing discovery. (a) Discovery methods. Parties may obtain discovery by one or more of the following methods: depositions upon oral

More information

LR2-400. Case management pilot program for criminal cases. A. Scope; application. This is a special pilot rule governing time limits for criminal

LR2-400. Case management pilot program for criminal cases. A. Scope; application. This is a special pilot rule governing time limits for criminal LR2-400. Case management pilot program for criminal cases. A. Scope; application. This is a special pilot rule governing time limits for criminal proceedings in the Second Judicial District Court. This

More information

All About Motions To Dismiss

All About Motions To Dismiss All About Motions To Dismiss Edna Sussman Motions to dismiss can be big winners or big losers. IT CAN BE one of the most satisfying experiences for a litigator. You pinpointed the fatal flaw in your opponent

More information

RULE 10 FUNDS HELD BY THE CLERK

RULE 10 FUNDS HELD BY THE CLERK RULE 10 FUNDS HELD BY THE CLERK 10.1 General. A Judge of the District Court may order that any monies in actions pending before the Court be invested in any local financial institution for safe keeping.

More information

IN THE SUPERIOR COURT FOR THE STATE OF ALASKA THIRD JUDICIAL DISTRICT AT ANCHORAGE

IN THE SUPERIOR COURT FOR THE STATE OF ALASKA THIRD JUDICIAL DISTRICT AT ANCHORAGE IN THE SUPERIOR COURT FOR THE STATE OF ALASKA THIRD JUDICIAL DISTRICT AT ANCHORAGE In the Matter of a ) Uniform Pretrial Order ) ) Administrative Order 3AO-03-04 (Amended) UNIFORM PRETRIAL ORDER In order

More information

Original FAQ Prepared July 30, 2013

Original FAQ Prepared July 30, 2013 2013-2014 COURT COSTS AND FEES - FREQUENTLY ASKED QUESTIONS Original FAQ Prepared July 30, 2013 Note: All of the answers to the following frequently asked questions (FAQ) reflect the interpretation of

More information

HAROLD CAMPING i ii iii iv v vi vii viii ix x xi xii 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52

More information

MIAMI-DADE COMMUNITY COLLLEGE LEGAL ASSISTANT PROGRAM COMPETENCY STATEMENT. PLA 2800-Family Law

MIAMI-DADE COMMUNITY COLLLEGE LEGAL ASSISTANT PROGRAM COMPETENCY STATEMENT. PLA 2800-Family Law MIAMI-DADE COMMUNITY COLLLEGE LEGAL ASSISTANT PROGRAM COMPETENCY STATEMENT PLA 2800-Family Law Course Description: This course provides students with an understanding of the principles that govern domestic

More information

A Practical Summary of the New Supreme Court Civil Rules for Clark Wilson LLP Insurance Clients

A Practical Summary of the New Supreme Court Civil Rules for Clark Wilson LLP Insurance Clients A Practical Summary of the New Supreme Court Civil Rules for Clark Wilson LLP Insurance Clients by: Jennifer Loeb Clark Wilson LLP tel. 604.891.7766 jrl@cwilson.com Edited by: Larry Munn Clark Wilson LLP

More information

Lesson 1. Health Information and Litigation ASSIGNMENT 1. Objectives. Criminal versus Civil Law

Lesson 1. Health Information and Litigation ASSIGNMENT 1. Objectives. Criminal versus Civil Law Health Information and Litigation ASSIGNMENT 1 Read this entire introduction. Then read Chapter 1 in your textbook, Legal Aspects of Health Information Management. When you ve read all of the material

More information

CHAPTER 42A. Case management of certain personal injuries actions. 42A.1. (1) Subject to paragraph (3), this Chapter applies to actions

CHAPTER 42A. Case management of certain personal injuries actions. 42A.1. (1) Subject to paragraph (3), this Chapter applies to actions CHAPTER 42A Case management of certain personal injuries actions Application and interpretation of this Chapter 42A.1. (1) Subject to paragraph (3), this Chapter applies to actions proceeding as ordinary

More information

Discovery in Bad Faith Insurance Claims: State of the Law, Successful Strategies. Teleconference Program Wednesday, March 29, 2006

Discovery in Bad Faith Insurance Claims: State of the Law, Successful Strategies. Teleconference Program Wednesday, March 29, 2006 Discovery in Bad Faith Insurance Claims: State of the Law, Successful Strategies Teleconference Program Wednesday, March 29, 2006 Topic III A. Who is suing? Does it matter? 1. Whether suit is brought by

More information

Table of Contents. LR 3.1 Filing Complaint by Electronic Means... 2. LR 3.2 Filing Complaint on Paper... 2

Table of Contents. LR 3.1 Filing Complaint by Electronic Means... 2. LR 3.2 Filing Complaint on Paper... 2 LOCAL CIVIL RULES Table of Contents LR 1.1 Definitions.................................................... 1 (a) Court........................................................ 1 (b) Presiding Judge................................................

More information

LABOR AND EMPLOYMENT LAW PARALEGAL

LABOR AND EMPLOYMENT LAW PARALEGAL LABOR AND EMPLOYMENT LAW PARALEGAL 2007 Revision and update drafted by Kimberly Browning, Holland & Hart, LLP. 2007 review by Brian Mumaugh, Esq., of Holland & Hart, LLP. Originally drafted by Kathy Sercel

More information

LOCAL CIVIL RULES UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA. (with revisions through January 2012)

LOCAL CIVIL RULES UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA. (with revisions through January 2012) LOCAL CIVIL RULES for the UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA (with revisions through January 2012) TABLE OF CONTENTS SCOPE AND PURPOSE OF LOCAL CIVIL RULES..................................

More information

PRIVATE ATTORNEY SERVICES DIVISION OF RISK MANAGEMENT BUREAU OF CLAIMS ADMINISTRATION INTRODUCTION TO BILLING GUIDELINES

PRIVATE ATTORNEY SERVICES DIVISION OF RISK MANAGEMENT BUREAU OF CLAIMS ADMINISTRATION INTRODUCTION TO BILLING GUIDELINES PRIVATE ATTORNEY SERVICES DIVISION OF RISK MANAGEMENT BUREAU OF CLAIMS ADMINISTRATION INTRODUCTION TO BILLING GUIDELINES The Division of Risk Management, Bureau of Claims Administration, (Division) is

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION. Case No. 5:07-CV-231-F

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION. Case No. 5:07-CV-231-F IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION Case No. 5:07-CV-231-F PAMELA L. HENSLEY, ) ) Plaintiff, ) ) v. ) ) PROPOSED JOINT JOHNSTON COUNTY BOARD

More information

International Institute for Conflict Prevention & Resolution www.cpradr.org

International Institute for Conflict Prevention & Resolution www.cpradr.org International Institute for Conflict Prevention & Resolution www.cpradr.org ECONOMICAL LITIGATION AGREEMENTS ( ELA ) FOR COMMERCIAL CONTRACTS AS A MEANS OF REDUCING CIVIL LITIGATION COSTS THE MODEL CIVIL

More information

In a recent Southern District of California decision, the court sent a

In a recent Southern District of California decision, the court sent a The Qualcomm Decision: Ethics In Electronic Discovery VICTORIA E. BRIEANT AND DAMON COLANGELO A recent decision reinforces the importance of a comprehensive electronic document management plan. In a recent

More information

Medical Malpractice Litigation. What to Expect as a Defendant

Medical Malpractice Litigation. What to Expect as a Defendant Medical Malpractice Litigation What to Expect as a Defendant Being named as a defendant in a malpractice suit may be your first exposure to civil litigation. You will probably wish it would just go away.

More information

Responding to a Complaint: Ohio

Responding to a Complaint: Ohio View the online version at http://us.practicallaw.com/3-578-2986 Responding to a Complaint: Ohio SETH ALAN SCHWARTZ, DINSMORE & SHOHL, WITH PRACTICAL LAW LITIGATION A Q&A guide to responding to a complaint

More information

Managing Jones Act Personal Injury Litigation The Vessel Owner s Perspective. Lawrence R. DeMarcay, III

Managing Jones Act Personal Injury Litigation The Vessel Owner s Perspective. Lawrence R. DeMarcay, III Managing Jones Act Personal Injury Litigation The Vessel Owner s Perspective by Lawrence R. DeMarcay, III Presented to the Offshore Marine Services Association / Loyola College of Law Industry Seminar

More information

IN THE CIRCUIT COURT OF COUNTY, ARKANSAS DIVISION PLAINTIFF

IN THE CIRCUIT COURT OF COUNTY, ARKANSAS DIVISION PLAINTIFF IN THE CIRCUIT COURT OF COUNTY, ARKANSAS DIVISION PLAINTIFF vs. CASE NO. CV DEFENDANT DEFENDANT S RESPONSES TO PLAINTIFF S FIRST INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS COMES NOW, Defendant,

More information

SSSHHHHH THERE S AN INSURANCE BROKER IN THE ROOM!

SSSHHHHH THERE S AN INSURANCE BROKER IN THE ROOM! ABA Section of Litigation 2012 Insurance Coverage Litigation Committee CLE Seminar, March 1-3, 2012: Hey! Give Me Back That Document! Privilege Issues in Insurance Coverage Disputes SSSHHHHH THERE S AN

More information

FALSE CLAIMS ACT: WHISTLEBLOWER LITIGATION, SIXTH EDITION

FALSE CLAIMS ACT: WHISTLEBLOWER LITIGATION, SIXTH EDITION NEW EDITION! FALSE CLAIMS ACT: WHISTLEBLOWER LITIGATION, SIXTH EDITION By James B. Helmer, Jr. This unique practice area is fraught with judicial pitfalls and circuit splits, challenging the most circumspect

More information

In March, 2012, Judge Robinson was appointed to fill the Third Circuit Court vacancy.

In March, 2012, Judge Robinson was appointed to fill the Third Circuit Court vacancy. JUDGE PHILLIP ROBINSON 3rd Circuit Court Room 611 I. BRIEF BIOGRAPHY Judge Phillip Robinson is a lifelong Nashvillian having graduated from Montgomery Bell Academy in 1968, the University of Tennessee

More information

I-2 FEDERAL RULES OF CIVIL PROCEDURE FOR THE UNITED STATES DISTRICT COURTS

I-2 FEDERAL RULES OF CIVIL PROCEDURE FOR THE UNITED STATES DISTRICT COURTS INTERNET RESOURCE Time Deadlines Federal Rules of Civil and Criminal Procedure Contents I-1 Introduction I-2 Federal Rules of Civil Procedure for the United States District Courts I-3 Federal Rules of

More information

CIVIL APPEALS PAMPHLET PRO BONO PROJECT FOR THE SPONSORED AND ADMINISTERED BY THE PRO BONO COMMITTEES FOR THE STATE BAR OF TEXAS APPELLATE SECTION

CIVIL APPEALS PAMPHLET PRO BONO PROJECT FOR THE SPONSORED AND ADMINISTERED BY THE PRO BONO COMMITTEES FOR THE STATE BAR OF TEXAS APPELLATE SECTION CIVIL APPEALS PAMPHLET FOR THE PRO BONO PROJECT SPONSORED AND ADMINISTERED BY THE PRO BONO COMMITTEES FOR THE STATE BAR OF TEXAS APPELLATE SECTION AND THE HOUSTON BAR ASSOCIATION APPELLATE SECTION IN THE

More information

FOURTH AMENDED OMNIBUS ORDER ON TRIAL SETTING, DISCOVERY AND PRODUCT IDENTIFICATION IN PERSONAL INJURY ASBESTOS LITIGATION (REVISED NOVEMBER, 2004)

FOURTH AMENDED OMNIBUS ORDER ON TRIAL SETTING, DISCOVERY AND PRODUCT IDENTIFICATION IN PERSONAL INJURY ASBESTOS LITIGATION (REVISED NOVEMBER, 2004) 11!02!04 18 :28 FAX 305 349 7059 CHIEF JUDGE FARINA L0002i023 IN THE CIRCUIT COURT OF THE l lei JUDICIAL CIRCUIT, 1N AND FOR MIAMI-DADS COUNTY FLORIDA GENERAL JURISDICTION DIVISION CASE NO. : 91-80,000

More information

Ligitation process in Denmark 1. Litigation process in Denmark. A brief summary of the procedures and workings of the litigation process in Denmark.

Ligitation process in Denmark 1. Litigation process in Denmark. A brief summary of the procedures and workings of the litigation process in Denmark. Ligitation process in Denmark 1 Litigation process in Denmark A brief summary of the procedures and workings of the litigation process in Denmark. Litigation process in Denmark 2 Content Who will handle

More information

In January 2009, Judge Smith became board certified as a Family Law Trial Advocate by the National Board of Trial Advocacy.

In January 2009, Judge Smith became board certified as a Family Law Trial Advocate by the National Board of Trial Advocacy. JUDGE PHILIP SMITH 4th Circuit Court Room 607 I. BRIEF BIOGRAPHY Judge Philip E. Smith graduated from the University of Tennessee College of Law in May of 1988. In October of 1988, Judge Smith went to

More information

Micronesian EXTERNSHIP PROGRAM

Micronesian EXTERNSHIP PROGRAM Micronesian EXTERNSHIP PROGRAM FIELD PLACEMENT HANDBOOK Kathleen M. Burch Director of Micronesian Externship Program 1422 West Peachtree Street, N.W. Atlanta, GA 30309 (404) 872-3593 (404) 873-3802 (Fax)

More information

Case 2:10-cv-00802-CW Document 90 Filed 02/02/15 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION

Case 2:10-cv-00802-CW Document 90 Filed 02/02/15 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION Case 2:10-cv-00802-CW Document 90 Filed 02/02/15 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION MURIELLE MOLIERE, Plaintiff, v. OPTION ONE MORTGAGE, et al., Defendants.

More information

SUPERIOR COURT OF ORANGE COUNTY PROBATE DIVISION

SUPERIOR COURT OF ORANGE COUNTY PROBATE DIVISION SUPERIOR COURT OF ORANGE COUNTY PROBATE DIVISION Trial/Hearing Rules for Probate Judge: Mary Fingal Schulte, Supervising Judge Judge: Gerald Johnston Judge: Randall Sherman Clerks: Dept. L72, Mary Torrez

More information

If you have been sued as a defendant in a civil case...keep reading.

If you have been sued as a defendant in a civil case...keep reading. If you have been sued as a defendant in a civil case...keep reading. Court procedures can be complex. This brochure was developed to help Ohioans who are considering representing themselves in court. It

More information

SUMMARY OF CONTENTS. C o m m o n R e p re s e n t a t i o n C o n f l i c t s

SUMMARY OF CONTENTS. C o m m o n R e p re s e n t a t i o n C o n f l i c t s SUMMARY OF CONTENTS Contents Preface vii xix Part I Introductory Materials 1 Chapter 1 Introduction 3 Chapter 2 Disqualification Motion Procedure 17 Chapter 3 Grounds for Disqualification 41 P a r t I

More information

Schneps, Leila; Colmez, Coralie. Math on Trial : How Numbers Get Used and Abused in the Courtroom. New York, NY, USA: Basic Books, 2013. p i.

Schneps, Leila; Colmez, Coralie. Math on Trial : How Numbers Get Used and Abused in the Courtroom. New York, NY, USA: Basic Books, 2013. p i. New York, NY, USA: Basic Books, 2013. p i. http://site.ebrary.com/lib/mcgill/doc?id=10665296&ppg=2 New York, NY, USA: Basic Books, 2013. p ii. http://site.ebrary.com/lib/mcgill/doc?id=10665296&ppg=3 New

More information

IN THE SUPREME COURT OF TEXAS

IN THE SUPREME COURT OF TEXAS IN THE SUPREME COURT OF TEXAS Misc. Docket No. 93-0141L APPROVAL OF LOCAL RULES OF CIVIL TRIAL OF THE 241ST JUDICIAL DISTRICT COURT OF SMITH COUNTY ORDERED: Pursuant to Rule 3a of the Texas Rules of Civil

More information

Addressing Abusive Lawyer Conduct in Relation to Litigation Proceedings

Addressing Abusive Lawyer Conduct in Relation to Litigation Proceedings Author: Attorney Dan A. Riegleman N63 W23965 Main Street Sussex, Wisconsin 53089 Prepared: 06/01/10 WHITE PAPER: DR2504 Addressing Abusive Lawyer Conduct in Relation to Litigation Proceedings There are

More information

INFORMATION FOR FILING AND DEFENDING A CIVIL CASE IN JUSTICE COURT

INFORMATION FOR FILING AND DEFENDING A CIVIL CASE IN JUSTICE COURT PINAL COUNTY Apache Junction Justice Court Eloy Justice Court Superior/Kearny Justice Court Maricopa/Stanfield Justice Court JUSTICE COURTS Casa Grande Justice Court Florence/Coolidge Justice Court Mammoth/San

More information

George Mason University School of Law PATENT LITIGATION AND DISPUTE RESOLUTION. Spring 2013. Tuesdays 8:00-9:50 P.M. Classroom 329 SYLLABUS

George Mason University School of Law PATENT LITIGATION AND DISPUTE RESOLUTION. Spring 2013. Tuesdays 8:00-9:50 P.M. Classroom 329 SYLLABUS George Mason University School of Law PATENT LITIGATION AND DISPUTE RESOLUTION Spring 2013 Tuesdays 8:00-9:50 P.M. Classroom 329 SYLLABUS INSTRUCTORS Rob Shaffer Finnegan, Henderson, Farabow, Garrett &

More information

COSTS AGREEMENT. work that is incidental to the above. The work we have not been instructed to do is:

COSTS AGREEMENT. work that is incidental to the above. The work we have not been instructed to do is: Please note: This is a template costs agreement and is intended to be used as a guide only. The terms of this agreement, including any rates contained in a schedule, are subject to change. Should you engage

More information

Locating Practice Materials

Locating Practice Materials PRACTICE MATERIALS Prepared for Bridge the Legal Research Gap, 2011 Originally prepared by Kelly Kunsch. Updated by Stephanie Wilson (2010) and Cheryl Nyberg (2011). These resources are meant to be representative,

More information

Case 2:09-cv-07349-AJM-KWR Document 19 Filed 02/10/10 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

Case 2:09-cv-07349-AJM-KWR Document 19 Filed 02/10/10 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA Case 2:09-cv-07349-AJM-KWR Document 19 Filed 02/10/10 Page 1 of 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA FIRST FINANCIAL INSURANCE COMPANY * CIVIL ACTION VERSUS * NO: 09-7349 JOSE ARRIAGA

More information

Case 1:09-cv-00554-JAW Document 165 Filed 01/23/12 Page 1 of 8 PageID #: 2495 UNITED STATES DISTRICT COURT DISTRICT OF MAINE

Case 1:09-cv-00554-JAW Document 165 Filed 01/23/12 Page 1 of 8 PageID #: 2495 UNITED STATES DISTRICT COURT DISTRICT OF MAINE Case 1:09-cv-00554-JAW Document 165 Filed 01/23/12 Page 1 of 8 PageID #: 2495 UNITED STATES DISTRICT COURT DISTRICT OF MAINE MICHAEL HINTON, ) ) Plaintiff, ) ) v. ) 1:09-cv-00554-JAW ) OUTBOARD MARINE

More information

Friday 31st October, 2008.

Friday 31st October, 2008. Friday 31st October, 2008. It is ordered that the Rules heretofore adopted and promulgated by this Court and now in effect be and they hereby are amended to become effective January 1, 2009. Amend Rules

More information

Foundations in Law Unit 4: Lawsuits and Liability: The Civil Justice System

Foundations in Law Unit 4: Lawsuits and Liability: The Civil Justice System Foundations in Law Unit 4: Lawsuits and Liability: The Civil Justice System Unit Overview How does the civil justice system hold people and corporations accountable for their actions? How does civil law

More information

TORT AND INSURANCE LAW REPORTER. Informal Discovery Interviews Between Defense Attorneys and Plaintiff's Treating Physicians

TORT AND INSURANCE LAW REPORTER. Informal Discovery Interviews Between Defense Attorneys and Plaintiff's Treating Physicians This article originally appeared in The Colorado Lawyer, Vol. 25, No. 26, June 1996. by Jeffrey R. Pilkington TORT AND INSURANCE LAW REPORTER Informal Discovery Interviews Between Defense Attorneys and

More information

EFFICIENTLY PREPARING A CASE FOR TRIAL ABA Distance CLE Teleconference January 12, 2010. A. I have previously presented a teleconference on

EFFICIENTLY PREPARING A CASE FOR TRIAL ABA Distance CLE Teleconference January 12, 2010. A. I have previously presented a teleconference on EFFICIENTLY PREPARING A CASE FOR TRIAL ABA Distance CLE Teleconference January 12, 2010 I. Scope of this presentation A. I have previously presented a teleconference on Woodshedding Witnesses and 60 Days

More information

BUSINESS COURT PROCEDURES FOR THE NINTH JUDICIAL CIRCUIT COURT, IN AND FOR ORANGE COUNTY, FLORIDA

BUSINESS COURT PROCEDURES FOR THE NINTH JUDICIAL CIRCUIT COURT, IN AND FOR ORANGE COUNTY, FLORIDA BUSINESS COURT PROCEDURES FOR THE NINTH JUDICIAL CIRCUIT COURT, IN AND FOR ORANGE COUNTY, FLORIDA SECTION 1 PHILOSOPHY, SCOPE AND GOALS 1.1 - Citation to Procedures 1.2 - Purpose and Scope 1.3 - Goals

More information

Guide to Small Claims Court

Guide to Small Claims Court Page 1 of 9 Guide to Small Claims Court 1. Introduction 2. What is Small Claims Court? 3. Who Can Sue and What Can You Sue About? 4. Before You Sue 5. When Must a Lawyer Represent Me in Small Claims? 6.

More information

MARYLAND STANDARDS OF PRACTICE FOR COURT-APPOINTED LAWYERS REPRESENTING CHILDREN IN CUSTODY CASES

MARYLAND STANDARDS OF PRACTICE FOR COURT-APPOINTED LAWYERS REPRESENTING CHILDREN IN CUSTODY CASES MARYAND JUDICIAL CONFERENCE COMMITTEE ON FAMILY LAW CUSTODY SUBCOMMITTEE HON. MARCELLA HOLLAND, CHAIR MARYLAND STANDARDS OF PRACTICE FOR COURT-APPOINTED LAWYERS REPRESENTING CHILDREN IN CUSTODY CASES TEXT

More information

Compulsory Arbitration

Compulsory Arbitration Local Rule 1301 Scope. Compulsory Arbitration Local Rule 1301 Scope. (1) The following civil actions shall first be submitted to and heard by a Board of Arbitrators: (a) (b) (c) (d) Civil actions, proceedings

More information

Counsel must be fully familiar with the Uniform Civil Rules for the Supreme Court 22 NYCRR Part 202.

Counsel must be fully familiar with the Uniform Civil Rules for the Supreme Court 22 NYCRR Part 202. JUSTICE GERALD E. LOEHR, J.S.C. Rockland County Supreme Court 1 South Main Street New City, New York 10956 Courtroom 1 Tel: (845) 483-8343 Fax: (845) 708-7236 Staff Bruce J. Pearl, Principal Law Secretary

More information

Title 31 MARYLAND INSURANCE ADMINISTRATION

Title 31 MARYLAND INSURANCE ADMINISTRATION 31.02.01.00 Title 31 MARYLAND INSURANCE ADMINISTRATION Subtitle 02 POWERS AND DUTIES HEARINGS Chapter 01 Hearings Authority: Insurance Article, 2-109 and 2-205 2-215; State Government Article, 10-206;

More information

Part VIII RULES GOVERNING PRACTICE IN THE TAX COURT OF NEW JERSEY TABLE OF CONTENTS

Part VIII RULES GOVERNING PRACTICE IN THE TAX COURT OF NEW JERSEY TABLE OF CONTENTS APPENDIX C - New Jersey Tax Court Rules Part VIII RULES GOVERNING PRACTICE IN THE TAX COURT OF NEW JERSEY Rule 8:1. Rule 8:2. Rule 8:3. Rule 8:4. TABLE OF CONTENTS Scope: Applicability Review Jurisdiction

More information

INSTRUCTIONS FOR PREPARING CASE MANAGEMENT PLAN

INSTRUCTIONS FOR PREPARING CASE MANAGEMENT PLAN INSTRUCTIONS FOR PREPARING CASE MANAGEMENT PLAN The following provisions apply to civil cases filed in the United States District Court for the Southern District of Indiana that are not exempt from filing

More information

The Enforceability of Mediated Settlement Agreements. By: Thomas J. Smith The Law Offices of Thomas J. Smith San Antonio, Texas

The Enforceability of Mediated Settlement Agreements. By: Thomas J. Smith The Law Offices of Thomas J. Smith San Antonio, Texas The Enforceability of Mediated Settlement Agreements By: Thomas J. Smith The Law Offices of Thomas J. Smith San Antonio, Texas NIGHTMARE ON MEDIATION STREET You mediate a case where the Plaintiff is suing

More information

S.B. 88 126th General Assembly (As Introduced)

S.B. 88 126th General Assembly (As Introduced) Elizabeth Dominic Bill Analysis Legislative Service Commission S.B. 88 126th General Assembly (As Introduced) Sens. Coughlin, Goodman BILL SUMMARY Requires the Superintendent of Insurance to establish

More information

Rules of the City of New York Title 61 - Office of Collective Bargaining Chapter 1 - Practice and Procedure

Rules of the City of New York Title 61 - Office of Collective Bargaining Chapter 1 - Practice and Procedure Rules of the City of New York Title 61 - Office of Collective Bargaining Chapter 1 - Practice and Procedure 1-01 Definitions 1-02 Representation Proceedings 1-03 Collective Bargaining 1-04 Mediation 1-05

More information

INSIGHT The litigation process in denmark

INSIGHT The litigation process in denmark INSIGHT The litigation process in denmark contents An overview 2 Where and who will handle the case 3 Who would handle the litigation? 3 Which court will handle the case? 3 The procedure steps you need

More information

Limited Action Suits

Limited Action Suits In General: What is a limited action suit? Per chapter 61, Limited Action cases in Kansas are civil cases where the dollar amount does not exceed $25,000.00, unless it is an unsecured debt, in which case

More information

CIVIL DISCOVERY STANDARDS* AUGUST 1999 [NOVEMBER 2003 DRAFT AMENDMENTS TO ELECTRONIC DISCOVERY STANDARDS]

CIVIL DISCOVERY STANDARDS* AUGUST 1999 [NOVEMBER 2003 DRAFT AMENDMENTS TO ELECTRONIC DISCOVERY STANDARDS] http://www.abanet.org/litigation/taskforces/electronic/amendments.doc CIVIL DISCOVERY STANDARDS* AUGUST 1999 [NOVEMBER 2003 DRAFT AMENDMENTS TO ELECTRONIC DISCOVERY STANDARDS] *The Standards, which appear

More information

Education & Training Plan Civil Litigation Specialist Certificate Program with Externship

Education & Training Plan Civil Litigation Specialist Certificate Program with Externship Testing Services and Programs 1200 N. DuPont Highway Dover, DE 19901 https://www.desu.edu/academics/mycaa Contact: Amystique Harris-Church 302.857.6143 achurch@desu.edu Education & Training Plan Civil

More information