2) the importance of specific and timely objections to discovery; and, 3) that “hide the ball” tactics won’t work. Michael Berman. Morgan demonstrates: (1) the need for timely discovery requests; (2) ...
As we approach the 10th anniversary of the amendment to Federal Rule of Civil Procedure 26(b)(1), which called for “proportionality” of discovery requests and responses, it is appropriate to provide ...