DISCOVERY Release No. 10

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1 DISCOVERY Release No. 10 Everything you need... Important Updates: E-Discovery - Preservation of Evidence - Requests & Responses - Privileges - Inadvertent Production - Cost Considerations & Cost-Shifting - Sanctions - Extensive Case Law Social Media Challenges Discovery in Family Law Cases Updated Rules & Statutes Discovery Forms Motions & Sanctions Deposition Notices & Requests Authorizations Foreign Countries Post-Judgment Discovery Interrogatories Invaluable Information: State Rules Addressing E-Discovery Requests for Production Requests for Admissions Specialized Subject Matter Chapters - Automobiles - Premises Liability - Workers Compensation - Products Liability - Professional Liability - and more! Research Taking Too Long? Take advantage of our free software. Fillable, interactive forms Access full text of cases and statutes in seconds Direct links to helpful websites Powerful search features View entire contents of the book Knowles Publishing, Inc. Fort Worth, TX

2 DISCOVERY Trial Lawyer s Series CHAPTER 1 LAW 1.1 Forms of Disclosure and Discovery Federal 1.2 Written Discovery Federal 1.3 Deposition Discovery Federal 1.4 Other Discovery Devices Federal 1.5 Expert Witness Discovery Federal 1.6 Scope of Discovery Federal 1.7 Specific Evidence and Things Discoverable Federal 1.8 Matter Not Discoverable Federal 1.9 Common Factual Issues in Pretrial Discovery Federal 1.10 Motions and Orders for Protection Federal 1.11 Sanctions and Discovery Abuse Federal 1.12 Checklist of Potential Mistakes in Discovery Federal 1.13 Foreign Depositions and Discovery Federal CHAPTER 2 RULES & STATUTES 2.1 Federal Rules of Civil Procedure Checklist 2.2 Federal Rules of Civil Procedure 2.3 Federal Rules of Evidence Checklist 2.4 Federal Rules of Evidence 2.5 Federal Statutes 2.6 Local Rules of the United States District Courts Discovery (Exemplars) 2.7 A Lawyer s Creed (Exemplar) 2.8 Local Rules CHAPTER 3 MOTIONS & SANCTIONS 3.1 Objections to Discovery 3.2 Compelling Discovery 3.3 Protecting Discovery 3.4 Sanctions 3.5 Discovery Relating to Entry Upon Land For Inspection 3.6 Motions to Deem Requests for Admissions Admitted 4.1 General 4.2 Planning Discovery 4.3 Depositions 4.4 Interrogatories 4.5 Requests for Admissions 4.6 Bill of Discovery CHAPTER 4 TACTICS & PROCEDURES KNOWLES PUBLISHING PAGE 1

3 4.7 Ideas 4.8 Other Forms of Discovery 4.9 E-Discovery 4.10 Sanctions 4.11 Ethics and Professionalism 4.12 Discovery Abuse 4.12 Complex Litigation 4.14 Insurance Litigation 4.15 The Cutting Edge 4.16 Pretrial Discovery Requirements Federal 4.17 Arranging and Using the Discovery Product 4.18 Making Written Attempts to Resolve Discovery Differences CHAPTER 5 DISCOVERY FORMS GENERAL 5.1 Disclosure 5.2 Written Interrogatories 5.3 Requests for Production 5.4 Requests for Admissions 5.5 Deposition Notices 5.6 Damages Personal Injury Case 5.7 Damages Wrongful Death Case 5.8 Confidentiality of Discovery Documents 5.9 Expert Designation 5.10 Expert Reports 5.11 Extension of Time For Discovery 5.12 Interrogatories Additional Sets 5.13 Inspection and Testing of Evidence 5.14 Inspection of Premises 5.15 Physical Examination of Plaintiff 5.16 Shortening Time for Discovery 5.17 Supplementation of Discovery Responses 5.18 Affidavits 5.19 Scheduling Orders 5.20 Privilege Log 5.21 Federal Rule of Civil Procedure 45 Subpoenas 5.22 Authorizations 6.1 Written Interrogatories 6.2 Requests for Production 6.3 Requests for Admissions 6.4 Uninsured/Underinsured Motorist Case 6.5 Construction Zone Accident 6.6 Tractor-Trailer Collision 6.7 Wrongful Death Case 6.8 Minor Plaintiff Case 6.9 Authorizations 6.10 Cases CHAPTER 6 AUTOMOBILE CASES KNOWLES PUBLISHING PAGE 2

4 7.1 Written Interrogatories 7.2 Requests for Production 7.3 Requests for Admissions 7.4 Security Case Checklist 7.5 Cases 8.1 Written Interrogatories 8.2 Requests for Production 8.3 Requests for Admissions 8.4 Cases 9.1 Written Interrogatories 9.2 Requests for Production 9.3 Requests for Admission 9.4 Cases 10.1 Written Interrogatories 10.2 Requests for Production 10.3 Requests for Admissions 10.4 Written Depositions 10.5 Cases Comments 11.1 Written Interrogatories 11.2 Requests for Production 11.3 Requests for Admissions 11.4 Cases 12.1 Written Interrogatories 12.2 Requests for Production 12.3 Cases CHAPTER 7 PREMISES LIABILITY CHAPTER 8 PRODUCTS LIABILITY CHAPTER 9 PROFESSIONAL LIABILITY CHAPTER 10 WORKERS COMPENSATION CHAPTER 11 FAMILY LAW CHAPTER 12 WRONGFUL DEATH KNOWLES PUBLISHING PAGE 3

5 13.1 Defendant s Motion for Discovery 13.2 Specific Motion for Discovery 13.3 Motion for Disclosure of Experts 13.4 Motion for Production 13.5 Cases 14.1 Written Interrogatories 14.2 Post-Judgment Discovery CHAPTER 13 CRIMINAL CHAPTER 14 MISCELLANEOUS INDEX KNOWLES PUBLISHING PAGE 4

PREMISES LIABILITY. Everything you need... Important Updates: Invaluable Information: Research Taking Too Long? Release No. 9

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