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action admission aﬂidavit amendment answer applicable arbitration argument attorney attorney’s Bond—Mor Civil Procedure claim client complaint conduct conﬁdential counsel counterclaim cross-claim damages Danforth decision defendant defendant’s deponent deposition determine disclose disclosure dismissal dispute documents Draft evidence examination expert facts factual Fed.R.Civ.P federal court federal question jurisdiction Federal Rule ﬁle ﬁled ﬁling ﬁnal ﬁnd ﬁrm ﬁrst hearing Hot Dog Enterprises inﬂuence interrogatories interview investigation involved issues judge jurisdiction jury lawsuit lawyer litigation Luger Lynn Burris matter mediation memo Mitchell non-party Northern Motor Homes objection obtain opposing party pendent party jurisdiction permit person personal jurisdiction plaintiff plaintiﬂ pleading Pozdak practice privilege questions Rainbow Computer reasonable record reﬂect relief represent require resolve response Rule 34 S.Ct seeking service of process settlement signiﬁcant speciﬁc statement statute subject-matter jurisdiction submit suﬂicient summary judgment tactics testimony tion Tri—Chem trial usually Vasquez witness