Two unusual, and quite useful, family law supplemental interrogatories
August 16, 2013
Though South Carolina family law attorneys are limited to fifty supplemental interrogatories, the boilerplate supplemental interrogatories I encounter are often ill designed to capture useful
Seeking protective orders for private investigator information
July 19, 2013
Since adultery is often a bar to alimony in South Carolina, family law attorneys here frequently employ private investigators (PIs). However, even when such PIs
Seeking procedural relief before seeking substantive temporary relief
February 23, 2013
My colleagues frequently recount war stories in which their attempts to obtain substantive relief on a temporary basis early in the case failed while subsequent
Objecting to discovery that you sought yourself
December 5, 2012
I often see attorneys object to discovery requests when those same attorneys request the same discovery. There are potential ethical violations and tactical problems in
The child custody interrogatory that often reveals more than it should
August 10, 2011
It’s typically hard to get useful information from child custody interrogatories. One question that often reveals more than it should is “Is there anything about
Stipulating to family court discovery
August 5, 2011
Unlike circuit court, there in no automatic discovery in South Carolina’s family court. See Rule 25, SCRFC. Most of the time, discovery is ordered at the
Disloyal collegiality in the prosecution and non prosecution of motions to compel
June 29, 2011
South Carolina attorneys are expected to be collegial. Part of that collegiality is a reluctance to file motions to compel discovery responses and a frequent
Verifying interrogatory answers
June 29, 2011
I prosecuted a motion to compel recently against an experienced attorney. One of the things I wanted his client compelled to do was verify the
