Preliminary Sections

• Author: Ashley Lipson
• Pages: 1-22

GUERRILLA DISCOVERY

FEDERAL AND STATES

BY ASHLEY S. LIPSON

HIGHLIGHTS

Guerrilla Discovery is the most complete and most comprehensive

book on the subject of Discovery ever written — All in a single volume.

In addition to being packed with countless forms, pleadings, cases (over 2,000 annotations), arguments, sample demands

and letters, lists, strategies and counter-strategies, the following are Unique to Guerrilla Discovery:

• DETAILS for every discovery device (With Rules, Samples, Forms, Cases, Arguments):

Requests for Admissions

Interrogatories

Depositions

Notices For Production and Inspection

Subpoenas

Foreign Pleadings

• Annotated Checklist of EVERY Discovery Defense and Objection ever used

• GUIDE for Avoiding Dirty Tricks (Attorneys are too often victimized, unknowingly)

• An ASSEMBLY of all Off‌icial Judicially Approved interrogatories (Expert's questions)

• What to say, and what not to say at depositions and motions

• Guide to Deposition Cross-examination

• A step-by-step roadmap for noticing, taking and defending depositions

• Off‌icial eDiscovery court approved protocols, and conventions

• Authoritative and Unique division of Work Product issues into precise degrees

• Extensive tactics, rules, decisions, statutes, tips, samples, checklists, and protocols

• Electronically Stored Information (ESI) resources, sources and guides

• Coverage of predictive coding and technology assisted review (TAR)

• Key Rules uniquely and thoroughly Annotated

• Special Glossary for electronic and digital discovery

• Special Chapter on Discovery Enforcement

AND MORE!

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