by R. Rogge Dunn and Trey Cox
Knock Opposing Counsel Off
Balance
Discovery provides
the best opportunities for throwing punches that force opposing counsel to
react rather than attack.
This 750-page
book of forms provides you the power to dominate the early discovery rounds.
Combining interrogatories, requests for admissions, and requests for
production into one strategically-interwoven document, these powerful
discovery documents will hit your opponents hard. You receive triple-threat
discovery forms for these types of cases:
Litigation favors the
quick and forceful attacker, yet limited time prevents many attorneys from
striking aggressively at the outset. Staying on the offensive is a proven
technique for achieving a strong settlement position. When you force your
opponents to spend their limited time reacting to your moves, you keep them
from advancing their cases. You buy yourself time to make your next moves,
push your case forward, and stay on the attack.
To attack aggressively at
the outset of discovery, begin with the pattern documents found in Rogge
Dunn’s new Triple-Threat Discovery Forms. Focusing on employment, business,
insurance, and personal injury cases, this collection creatively weaves
together interrogatories, requests for admissions, and requests for
production into a powerful first-strike discovery document.
59 Bonus Discovery Forms
Triple-Threat
Discovery Forms
also contains deposition outlines, model letters, pattern interview
questions, intake questionnaires, and other discovery aids. For example:
Depositions
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11
deposition outlines
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Pointers for clients
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Preparation of experts
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Preparation of witnesses
Letters
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Letter to corporate client re ways to maintain attorney/client privilege
during client’s investigation
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Doctor’s protection
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Requesting doctor reduce lien
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3 notices to preserve evidence
Plus
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2 protective orders
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3 pattern interviews
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2 intake questionnaires
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Interview of potential expert witness
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Memo to paralegal re items needed for hearings and depositions
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Agreement regarding production of documents for settlement purposes only
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And many more
How Pre-Drafted Discovery Documents Help
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Reduce drafting time.
Whether you copy and paste selected questions from the free companion
CD, dictate from the book, or customize whole forms, using pre-drafted
questions and requests can save you hours.
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Elicit more complete
answers. The comprehensive definitions and clear, direct phrasing of the
questions and requests will reduce the number of objections and
non-responsive answers you receive.
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Avoid omissions. The
extensive documents in Triple-Threat Discovery Forms will bring to mind
fertile topics for exploration, and the detailed pattern questions and
requests will highlight the best areas of inquiry.
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Produce quality work.
By starting with questions and requests that have already been used and
revised several times, your first draft will read like a polished final
copy.
Updated annually. ISBN
1-58012-101-2 Book price: $79.00
J7
View and Print the Brochure


Related Titles:
Guerrilla Discovery
Handling Federal Discovery
How to Prepare for, Take
and Use a Deposition
Model Interrogatories
California Pretrial
Practice & Forms
Florida Pretrial Practice
Illinois Pretrial
Practice
New York Pretrial
Practice
Texas Pretrial Practice
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