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Guerrilla Discovery - James Publishing by Ashley S. Lipson

Guerrilla Discovery - James Publishing

By Ashley S. Lipson


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Strike and parry quickly and effectively during your next discovery confrontation. This battle-proven, tactician’s guide offers dozens of creative forms, checklists, arguments, and strategies. Use it to: firmly establish your allegations, learn of additional counts or causes of action, discover and weaken the enemy’s defenses, quickly eliminate fictitious and boilerplate defenses, obtain concessions and admissions, and coerce settlement.

Most litigation and settlement outcomes are determined in quarrelsome discovery fights. Coercion and confrontation are usually necessary to obtain evidence on the hotly-contested issues.

To help you win more of these important discovery skirmishes, Ashley Lipson’s Guerrilla Discovery offers dozens of clever strategies, novel arguments, direct answers, cautionary instructions, helpful timelines, tactically-annotated rules, and over one hundred innovative forms that will help you:

  • Capture evidence establishing your claims and defenses
  • Secure admissions
  • Settle issues and disputes
  • Impeach the enemy and its witnesses
  • Uncover what the enemy is hiding
  • Learn what the enemy has on you

You receive complete and targeted sets of strategically-annotated discovery documents, complete with responses and shields for each weapon: requests for admissions, interrogatories, deposition checklists, notices for production, and notices for inspection.

Guerrilla Discovery is designed to help you efficiently and with less aggravation get more from your discovery efforts:

  • Firmly establish your allegations
  • Learn of additional counts or causes of action
  • Discover and weaken the enemy’s defenses
  • Quickly eliminate fictitious and boilerplate defenses
  • Obtain concessions and admissions
  • Coerce settlement

Use Ashley Lipson’s Guerrilla Discovery to strike and parry quickly and painfully during your next discovery confrontation.

Note: Product is fulfilled by James Publishing. 

Publish Date 08/17/2018
Publish Frequency Annually
Product Line Wolters Kluwer Legal & Regulatory U.S.
ISBN 9781945421976
SKU 10066315-0001
Table of Contents

CHAPTER 1. Fundamental Overview
CHAPTER 2. Is It Discoverable?
CHAPTER 3. Electronic, Digital and Other Media
CHAPTER 4. Weapon Selection and Attack
CHAPTER 5. Requests for Admissions
CHAPTER 6. Interrogatories
CHAPTER 7. Notices for Production
CHAPTER 8. Requests for Inspection
CHAPTER 9. Physical and Mental Examinations
CHAPTER 10. Depositions
CHAPTER 11. Subpoena Power
CHAPTER 12. Defending and Responding in General
CHAPTER 13. Defending Discovery’s Limits
CHAPTER 14. Using The Work Product Doctrine
CHAPTER 15. Using Traditional Privileges
CHAPTER 16. Exposing Burdensome and Abusive Tactics
CHAPTER 17. Enforcement