“Shotgunning” motions to compel discovery

May 6, 2011

While the rules of civil procedure don’t create a distinction, there are really two types of motions to compel discovery.  The first type of motion

Discovery in family court: shotgun or rifle approach?

January 15, 2011

Many of these blogs are inspired by young attorneys I am informally mentoring.  This one was inspired by a query as to the sort of

A “shot across the bow”: issuing discovery as a method of encouraging settlement

December 5, 2010

Quite often in my family law cases I will issue written discovery along with a settlement proposal. This is a strategy I see few other

When to file a contested marital dissolution action before negotiating and when not to request a temporary hearing when filing a contested family court case

July 4, 2010

It is my experience that most family law attorneys in South Carolina reflexively file a motion for temporary relief when filing a contested family court

Gone fishing

May 25, 2010

Last Friday I attended a motion in which the primary issue was whether my client’s discovery request was a “fishing expedition.”  The term “fishing expedition”

Countering weasely responses in discovery and pleadings

March 16, 2010

“Weaseling out of things is important to learn. It’s what separates us from the animals! Except the weasel.” -- Homer Simpson A common complaint among family law

South Carolina Supreme Court allows writ of certiorari to challenge discovery order

September 22, 2009

The September 21, 2009 Supreme Court opinion in Hollman v. Woolfson, 384 S.C. 571, 683 S.E.2d 495 (2009) approves an unusual use of a writ of certiorari:

The pitfalls of cursory standard interrogatory responses

July 28, 2009

The Court of Appeals’ decision to affirm the family court’s award of custody to the father in its July 28, 2009 opinion in Divine v.

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