Saturday, February 04, 2006 12:20:44 PM
This is my first chance to read Whizzer's definition of a discovery schedule, which was recently delayed until next Friday. i. e.,
"The discovery schedule, ....sets forth the time periods by which the parties will complete discovery, which includes witnesses to be deposed, documents to be subpoened and interrogatories."
Man. This seems like a tall order. Especially if you intend to depose people around the world.
But I'm still a little confused about the two-step approach.
First step: Keep discovery at a minimum, and then go for summary judgment.
Second step: Go the "complex" route,with all guns blazing, including probable shots in Finland, Sweden, South Korea, etc.
Questions:
1. When should the judge agree/disagree on the "complex case" question?
2. How does this two-step process work?
3. If you were handling this case, would you have waited to make your list of potential witnesses and interrogatories, until the last minute, requiring an extension?
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