Maryland Discovery and Problems and Solutions (MSBA)

Index

• Front Matter
• Foreword
• Introduction
• Section 1 Interrogatories, Document Requests, Requests for Admission, and Motions for Mental and Physical Examinations
• Chapter 1 Framing and Scope of Proper Interrogatories
• Chapter 2 Interrogatories—Numerosity: Parts and Subparts
• Chapter 3 Interrogatories—Propriety of Definitions and Instructions
• Chapter 4 The Timing of Interrogatories and Requests for Production—How Soon Can You Ask, and When Is It Too Late?
• Chapter 5 Interrogatories—Sufficiency of Objections
• Chapter 6 Sufficiency and Supplementation of Interrogatory Answers
• Chapter 7 Interrogatories—Use In Court
• Chapter 8 Document Requests—Numerosity, Propriety, Timing, and Sufficiency of Objections
• Chapter 9 Discovery of Electronically Stored Information
• Chapter 9A Discovery of Social Network Evidence From A Former Employee
• Chapter 10 Discovery of Witness Statements
• Chapter 11 Privilege Logs
• Chapter 12 Inadvertent Disclosure of Privileged Material
• Chapter 13 Motions for Mental Or Physical Examination
• Chapter 14 Request for Admission
• Section 2 Depositions
• Chapter 15 Notice of Deposition—Timing
• Chapter 16 Taking A Deposition—The Basics
• Chapter 17 Depositions—Making Procedural and Evidentiary Objections
• Chapter 18 Asserting Privileges During Deposition
• Chapter 19 Instructing A Witness Not To Answer A Question
• Chapter 20 Misconduct By Counsel At A Deposition, Including Coaching The Witness
• Chapter 21 Video Depositions, and Remote Video Depositions
• Chapter 22 Who May Attend A Deposition?
• Chapter 23 Submission of Deposition Transcript To Witness for Review and Signature
• Chapter 24 Compensation for Treating Physician's Deposition Preparation and Testimony
• Chapter 25 Depositions of Corporations and Other Entities Under Rule 2-412(D)
• Chapter 26 Discovery of Oral Communications and Privileged Documents Provided To A Witness
• Chapter 27 Discovery of Jury Consultant and Focus Group Materials and Related Communications
• Chapter 28 Ethical Considerations In Representing Your Corporate Client's Employees In Deposition
• Chapter 29 Discovery of Foreign Citizens and Residents
• Chapter 30 Use of Adverse Party's Deposition At Trial
• Chapter 31 Use At Trial of Deposition of Unavailable Witness
• Chapter 32 Use of Deposition for Impeachment At Trial
• Section 3 Experts
• Chapter 33 The Timing of Expert Depositions
• Chapter 34 Timing and Supplementation of Expert Disclosures
• Chapter 35 Expert Disclosures—Hybrid Fact|Expert Witnesses
• Chapter 36 Taking An Expert's Deposition—The Basics
• Chapter 37 Discovery of Oral Communications and Privileged Documents Shared With Experts
• Chapter 38 Discovery of Facts Known Or Opinions Held By Expert Not Expected To Testify At Trial
• Chapter 39 Deposing Opposing Party's Former Expert In The Same Case
• Chapter 40 Discovery of Draft Report By Testifying Expert
• Chapter 41 Discovery Pursuant To Stevenson-Daubert
• Chapter 42 Reasonableness of Fees and Expenses Charged To Deposing Party By Adverse Expert
• Section 4 Sanctions and Protective Orders
• Chapter 43 Fed. R. Civ. P. 26(A) Disclosures and Fed. R. Civ. P. 37(C) Motion for Failure To Disclose, Misleading Disclosures Or Refusal To Admit, and Application To Maryland Procedure
• Chapter 44 Sanctions for Bad Faith Discovery Requests: The Requirement of A Signature On Discovery Requests, Responses and Objections
• Chapter 45 Motion To Compel Discovery
• Chapter 46 Motion for Protective Order
• Chapter 47 Rule 2-432(A) Sanctions for Failure of A Party To Attend Its Own Deposition Or Respond To Interrogatories Or Document Production Requests
• Chapter 48 Nonproduction, Spoliation, Discovery Violations, and Adverse Inference
• Chapter 49 Sanctions for Failure To Comply With Court-Ordered Discovery
• Chapter 50 Chart Summarizing Discovery Sanctions Under Maryland Law
• Appendix A Maryland Rules
• Appendix B Discovery Guidelines of The Maryland State Bar Association
• Appendix C-1 Form Interrogatories In Maryland, Including Form Instructions and Definitions
• Appendix C-2 Form Objections To Interrogatories
• Appencix D Principles for The Discovery of Electronically Stored Information In Civil Cases
• Appendix E Maryland State Bar Association Code of Civility
• Appendix F The American College's Interim Guidelines On Remote Video Depositions and Examinations for Discovery
• About The Authors
• ABOUT THE AUTHORS