Respecting the ongoing duty to supplement written discovery responses
February 5, 2016
South Carolina case law recognizes the fundamental importance of discovery to preparing a lawsuit for trial: The primary objective of discovery is to ensure that
The risk of sending South Carolina family law clients to counseling
September 9, 2015
Many family law clients in the initial stage of custody or divorce litigation could benefit from counseling. Whether it is developing better coping methods for
Every Social Security Statement tells a story
April 25, 2015
The Social Security Statement, mailed annually or available for order online at http://www.socialsecurity.gov/forms/ssa-7050.pdf, is often the most valuable piece of financial information for alimony and
Discovery for defending domestic violence allegations in family court cases
March 19, 2015
Allegations of domestic violence in family court cases are often akin to shock grenades: intend to knock the other party back and on the defensive.
Remedies for the evasive deposition witness
September 18, 2014
Few areas of litigation practice are more frustrating than deposing an evasive, hostile or obnoxious witness. In the courtroom setting, a witness who acts these
Common Rule 11 violations in discovery requests and objections
April 3, 2014
I’m not sure my fellow members of the bar are aware they are doing it, but I see a whole lot of Rule 11 violations
The two types of motions to compel discovery
March 30, 2014
Although the rules of civil procedure don’t differentiate them, there are really two distinct types of motions to compel discovery: one addressing the untimeliness of
Should one verify what doesn’t have to be verified?
March 24, 2014
An old mentee of mine asked me if he should verify pleadings given that Rule 11(a) of the South Carolina Rules of Civil Procedure no
