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

"Getting the truth out of your own client can be difficult. I have found a trick that always works. After your client has told you his side of the story, look him in the eye and say, 'I believe everything you told me. But in order to be ready for the enemy, I need you to tell me something else. When that #!$?&! comes into court, what…?' The truth is sure to follow this question." §1.51

"Is It Discoverable?" annotated checklist. Here are fast, direct, and detailed answers to the most common discovery questions. Includes "Six Degrees of Discoverability" quick-reference chart. §2.10

"Countless times practitioners waltz into court, dumb and happy because they have under their arms papers labeled 'business records,' as if those papers were self-authenticating and self-admitting. They are not! This blissful ignorance, however, is counterbalanced by attorneys on the other side who, upon hearing the magic words 'business records,' lay down and assume that there are no defenses to admissibility. Both positions are incorrect." §5.34

23 requests for admission that are specifically designed to solve document admissibility problems ignored by discovery rules and universally omitted by forms books and treatises. §5.34

"A well-drafted set of interrogatories should never receive fast answers. On the contrary, you know you have done your job when the enemy is forced to duck, weave, squirm and refuse. Take the greatest pride in questions that simply cannot be answered by the enemy." Dozens of artfully-crafted, precisely-focused, and complete sets of interrogatories are provided. They establish elements, identify and locate evidence, attack pleadings, and assail experts. Chapter 6

How to mix boilerplate and specific facts to create effective objections, with checklist of objections. §6.65

Tricks for catching liars, showing bias, not accepting evasive answers (including "I don't remember"), establishing a range for quantitative information, and generally handling difficult deponents. §10.52

How to counter verbal and nonverbal coaching, coaching off the record, and obnoxious objections. §10.53

Here is the dream responsive pleading … a Motion for Protective Order that contains every possible challenge to every type of discovery request. Form 12.1

Before responding, review these 12 grounds for objecting to discovery requests. Then check the lists of objections specific to each discovery device. §12.30

16 objections to physical examinations. §9.54

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