Q: Need help to prepare civil discovery motions to compel on a Limited Scope basis.
I'm the plaintiff. The law firm for the defendants are jerking me around with BS objections and responses to discovery. I'm looking for a lawyer who can assist me on a Limited Scope basis to prepare high quality motions to compel discovery which are dead bang winners.
Please contact me if you do LSR's along with your rates.
A: All real litigators know there is no such thing as a "dead bang winner" discovery motion. Generally, judges do not like these types of motions. The key to effective discovery is precise and clear drafting of the discovery, clear necessity for the particular discovery, and well-documented efforts to reasonably resolve discovery disputes. After reasonably (maybe beyond reasonably) attempting to resolve all issues, only then, but promptly and certainly well within the time limit to bring such a motion, can you hope to prevail. By the way, if you hope to get even some portion of the attorney fees for the motions back, you will have to let the court and the other side know the identity of the lawyer you hired on a limited scope basis. That is because the amount of sanctions awarded must be supported by evidence (declaration).
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