Generating avenues for trial evidence from an opposing party’s discovery
September 10, 2024
While most discovery requests are routine or boilerplate, some discovery requests can offer insight into the opposing party’s thinking. Such discovery requests provide fodder for
August 7, 2024
The August 7, 2024, Supreme Court opinion in E.G. and J.J. v. SCDSS, held that adoption records, if relevant, were subject to disclosure in civil
No one enjoys answering discovery—still don’t fight your attorney on responding to it
February 9, 2024
One of the least pleasant tasks in any litigation is responding to discovery. Little of what is produced in responding to discovery actually gets used
The danger of sandbagging witness lists and trial exhibits in discovery responses
November 11, 2023
The four standard interrogatories that are relevant to family court are basically questions about witnesses, expert witnesses, and trial exhibits. Any initial request for production
Interrogatory answers need to be accurate, complete, and minimal
October 8, 2020
My standard procedure in answering interrogatories is to obtain an opposing party’s questions as a word document, cut and paste into my own responsive word
An evasive or incomplete answer is to be treated as a failure to answer
October 14, 2019
I find it curious that attorneys routinely treat incomplete or evasive discovery responses as no big deal. From my reading, Rule 37(a)(3), SCRCP, could not
The pitfalls of boilerplate supplemental interrogatories
September 14, 2019
I’m shocked how often I encounter supplemental interrogatories in family court in which the issuing attorney has clearly given no thought into how interrogatories might
The only two goals of responding to discovery
March 10, 2018
There are common bad practices of responding to discovery. One often sees responses that are incomplete and only partially respond to the request. The rules
