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STRATEGIC DISCOVERY PLANNING
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accident affidavit answer Assume you represent attorney-client attorney-client privilege attorney's Barthold Chapter Civil Procedure client conduct copy court damaging defendant defendant's deponent deponent's depose deposition hearing discovery devices documents Dombroff draft employees evidence examination expenses expert facts failure Federal Rule formal discovery identify Imwinkelried informal discovery inspection interview investigator issue Johnson judge jurisdictions lawyer litigation matter ment Metro Steel motion to compel negotiation notice objection obtain opponent opponent's opposing attorney opposing counsel options party permit person plaintiff pre-need prepare pretrial discovery privilege problem product liability production request protective order question reasonable records relevant represent Enterprise Properties represent Janet Lee requests for admission require respond Rule 34 sanctions Schlagenhauf seek serve Sherwood Construction statement stipulation stove subpoena Suppose supra tactical Taser Taser gun testify testimony theory tion Trial Law Twin Oaks waiver witness workbooks