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admission affidavit affirmative defenses amend answer appear apply appropriate argument attorney attorney's Casebook Civil Procedure claim client complaint conduct Corp counsel counterclaim cross-claim damages Danforth decision defendant defendant's denied deponent deposition determine disclosure discovery dismissal documents Draft evidence examination expert F.Supp facts factual Fed.R.Civ.P federal court Federal Rules hearing injunction interrogatories interview investigation involved issues judge jurisdiction jury lawyer limited litigation Luger Lynn Burris Marathon Sports matter memo ment Mitchell motion non-party Northern Motor Homes objection obtain oral permit person personal jurisdiction plaintiff pleading Pozdak practice present pretrial conference privilege problems protective order questions Rainbow Computer reasonable record relief represent require response Rule 34 Rules of Civil S.Ct sanctions seeking service of process settlement Snow Cat specific statement statute Stenson stipulation subject-matter jurisdiction subpoena summary judgment tactics testimony tion trial preparation materials usually Vasquez Whirling Dervish witness