Effective Discovery Techniques and Strategies That Work

Effective Discovery: Techniques and Strategies That Work is a comprehensive practical guide to "paper" discovery and related undertakings—discovery conferences, plans, reports, and orders; disclosures; interrogatories; requests for production; physical and mental exams; requests for admission; electronic discovery; motions; and subpoenas. This informative and eminently readable text takes litigators through the stages of discovery, addressing: discover objectives, planning, strategies, ethics, and rules; when and how to use discovery devices alone and in combination; how to assess which discovery devices will work best in your circumstances; how to draft discovery designed to get needed information; how to respond when the other side is evading—or refusing—your discovery; proportionality—assessing when enough is enough, too much, or not nearly enough; what judges want and don’t want—and the Laws of Unintended Consequences and What Goes Around, Comes Around. The book is a companion to NITA’s best-selling The Effective Deposition. Together, the two volumes provide an in-depth guide to discovery in all its forms.