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action amendment amount answer attomey attorney beneﬁts burden certiﬁcation Civil Procedure claim client complaint conﬁdential copy Corp corporation court order cross-examination damages decedent decedent’s defendant defendant’s deﬁnition denied deponent discovery request discovery responses employees evidence examination exhibits expense expert witness facts FEDERAL PRACTICE Federal Rules ﬁle ﬁled ﬁling ﬁnal ﬁnd ﬁrst ﬁve identiﬁcation inclusive dates injury interro interrogatories issues judge jury lawyer limited litigation materials matter motion to compel name and address notice Objection on ground obtained opinion opponent opponent’s party’s person plaintiff prepared pretrial conference pretrial discovery prior prior restraint privilege production of documents Products Liability protective order purpose pursuant questions reasonable records relevant request for production requests for admissions Rule 34 Rules of Civil seek served sought speciﬁc statement stipulation subpoena subpoena duces tecum Supp supra note telephone deposition testimony tion trial videotape deposition voir dire work-product written