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Author Name Fried Rogers Goldberg
920 Pages  
Published date 2011
ISBN no. 978-1-57625-667-1
 
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Title
Acknowledgments
Dedication
Forward
About the Editor
CHAPTER 1: DEALING WITH POTENTIAL CLIENTS AND SIGNING UP THE CASE
1-000 DEALING WITH POTENTIAL CLIENTS AND SIGNING UP THE CASE
1-001 NEW CLIENT INFORMATION SHEET
1-002 FEE AGREEMENT CONTRACT
1-003 LETTER TO CLIENT ENCLOSING FEE AGREEMENT CONTRACT
1-004 MEDICAL AUTHORIZATION TO BE SIGNED BY CLIENT
1-005 EMPLOYMENT RECORDS AUTHORIZATION TO BE SIGNED BY CLIENT
1-006 LETTER TO CLIENT: INVESTIGATING CLAIM BEFORE DECIDING WHETHER TO TAKE CASE
1-007 AUTHORIZATION TO TRANSFER FILE FROM PREVIOUS ATTORNEY
1-008 LETTER TO PREVIOUS ATTORNEY REQUESTING CLIENT’S FILE
1-009 LETTER TO CLIENT: CO-COUNSEL AGREEMENT
1-010 LETTER TO REFERRING ATTORNEY MEMORIALIZING CO-COUNSEL AGREEMENT
1-011 FORMAL ASSOCIATION AGREEMENT
1-012 THANK-YOU LETTER TO ATTORNEY FOR REFERRAL
1-013 THANK-YOU LETTER TO NON-ATTORNEY FOR REFERRAL
1-014 REJECTION LETTER: PERSONAL INJURY CASE
1-015 REJECTION LETTER: MEDICAL MALPRACTICE CASE
1-016 CONFLICT WAIVER
1-017 CHECKLIST FOR ESTABLISHING NEW CLIENT RELATIONSHIP
CHAPTER 2: NOTIFICATION OF REPRESENTATION AND PRESERVING EVIDENCE
2-000 NOTIFICATION OF REPRESENTATION AND PRESERVING EVIDENCE
2-001 LETTER OF REPRESENTATION TO DEFENDANT REQUESTING INSURANCE INFORMATION
2-002 AFFIDAVIT FOR REQUESTING POLICY LIMITS
2-003 LETTER OF REPRESENTATION TO INSURER REQUESTING POLICY LIMITS
2-004 ANTE LITEM NOTICE TO CITY
2-005 ANTE LITEM NOTICE TO COUNTY
2-006 NOTICE FOR STATE TORT CLAIMS ACT
2-007 GENERAL SPOLIATION LETTER
2-008 TRUCKING SPOLIATION LETTER
2-009 LAW ENFORCEMENT MISCONDUCT SPOLIATION LETTER
2-010 ESCALATOR/ELEVATOR SPOLIATION LETTER
2-011 NURSING HOME SPOLIATION LETTER
2-012 SPOLIATION LETTER TO PRESERVE SURVEILLANCE TAPES
2-013 LETTER PLACING UM INSURER ON NOTICE OF CLAIM
2-014 LETTER PLACING CLIENT’S INSURER ON NOTICE OF MEDPAY CLAIM
2-015 CHECKLIST FOR NOTIFICATION OF REPRESENTATION AND PRESERVING EVIDENCE
CHAPTER 3: INVESTIGATION OF LIABILITY
3-000 INVESTIGATION OF LIABILITY
3-001 LETTER TO INSURER REQUESTING CLIENT’S RECORDED STATEMENT
3-002 LETTER REQUESTING ACCIDENT REPORT FROM POLICE
3-003 OPEN RECORDS ACT REQUEST TO POLICE FOR ENTIRE INVESTIGATIVE FILE
3-004 OPEN RECORDS ACT REQUEST FOR 911 TAPES/CAD REPORT
3-005 LETTER REQUESTING CERTIFIED COPY OF GUILTY PLEA
3-006 LETTER TO GBI REQUESTING AUTOPSY REPORT
3-007 LETTER TO GBI REQUESTING TOXICOLOGY REPORTS
3-008 FREEDOM OF INFORMATION ACT REQUEST TO FEDERAL GOVERNMENTAL ENTITY
3-009 FREEDOM OF INFORMATION ACT REQUEST TO FEDERAL MOTOR CARRIER SAFETY ADMINISTRATION
3-010 OPEN RECORDS ACT REQUEST TO MARTA FOR ELEVATOR/ESCALATOR INCIDENT
3-011 OPEN RECORDS ACT REQUEST TO DEPARTMENT OF HUMAN RESOURCES
3-012 OPEN RECORDS ACT REQUEST TO ANIMAL CONTROL
3-013 OPEN RECORDS ACT REQUEST TO POLICE FOR CRIMINAL HISTORY OF PROPERTY
3-014 OPEN RECORDS ACT REQUEST TO INTERNAL AFFAIRS/POLICE DEPARTMENT FOR EXCESSIVE FORCE
3-015 OPEN RECORDS ACT REQUEST TO DEPARTMENT OF LABOR
3-016 CHECKLIST FOR INVESTIGATION OF LIABILITY
CHAPTER 4: PROVING YOUR CLIENT’S INJURIES AND DAMAGES
4-000 PROVING YOUR CLIENT’S INJURIES AND DAMAGES
4-001 LETTER TO CLIENT REQUESTING DAMAGES INFORMATION IN PERSONAL INJURY CASE
4-002 LETTER TO CLIENT REQUESTING DAMAGES INFORMATION IN WRONGFUL DEATH CASE
4-003 LETTER TO CLIENT REQUESTING STATUS OF MEDICAL TREATMENT
4-004 LETTER TO EMPLOYER WITH WAGE LOSS VERIFICATION
4-005 WAGE LOSS VERIFICATION TO EMPLOYER FOR PERSONAL INJURY CLAIM
4-006 REQUEST FOR TAX RETURNS TO INTERNAL REVENUE SERVICE
4-007 IRS Form 4506 for Requesting Tax Returns
4-008 REQUEST FOR CLIENT’S PERSONNEL FILE FROM EMPLOYER
4-009 REQUEST FOR CLIENT’S MEDICAL RECORDS
4-010 CERTIFICATION OF MEDICAL RECORDS AS BUSINESS RECORDS
4-011 NOTICE OF INTENT TO INTRODUCE CERTIFIED COPY OF MEDICAL RECORDS
4-012 LETTER TO DOCTOR REQUESTING MEDICAL NARRATIVE
4-013 MEDICAL NARRATIVE FORM
4-014 NOTICE OF INTENT TO INTRODUCE MEDICAL NARRATIVE
4-015 OBJECTION TO USE OF MEDICAL NARRATIVE
4-016 REQUEST FOR CLIENT’S PHARMACY RECORDS
4-017 REQUEST FOR CLIENT’S MEDICAL BILLS
4-018 REQUEST FOR DEATH CERTIFICATE
4-019 LETTER FOLLOWING UP ON REQUEST FOR MEDICAL RECORDS OR BILLS
4-020 LETTER REQUESTING UPDATED MEDICAL RECORDS
4-021 REQUEST FOR DIAGNOSTIC FILMS
4-022 MEDICAL EXPENSE SUMMARY
4-023 LETTER REQUESTING MILITARY SERVICE RECORDS
4-024 Military Service Records Form 180
4-025 CHECKLIST FOR PROVING YOUR CLIENT’S INJURIES AND DAMAGES
CHAPTER 5: COMPLAINTS
5-000 COMPLAINTS
5-001 AUTOMOBILE ACCIDENT: TWO VEHICLES
5-002 AUTOMOBILE ACCIDENT: PASSENGER
5-003 AUTOMOBILE ACCIDENT: PEDESTRIAN
5-004 AUTOMOBILE ACCIDENT: FAMILY PURPOSE DOCTRINE
5-005 AUTOMOBILE ACCIDENT: JOHN DOE
5-006 BOATING ACCIDENT COMPLAINT
5-007 WRONGFUL DEATH SECTION OF COMPLAINT
5-008 PUNITIVE DAMAGES SECTION OF COMPLAINT
5-009 EMPLOYER LIABILITY SECTION OF COMPLAINT
5-010 TRUCKING ACCIDENT
5-011 PREMISES LIABILITY: SLIP AND FALL, FOREIGN SUBSTANCE
5-012 PREMISES LIABILITY: SLIP AND FALL, STATIC DEFECT
5-013 PREMISES LIABILITY: NEGLIGENT SECURITY
5-014 ESCALATOR/ELEVATOR ACCIDENT
5-015 DOG BITE
5-016 FALSE ARREST BY PREMISES OWNER
5-017 EMPLOYEE ASSAULT ON PREMISES
5-018 EXCESSIVE FORCE POLICE MISCONDUCT
5-019 MEDICAL MALPRACTICE: PHYSICIAN
5-020 MEDICAL MALPRACTICE AFFIDAVIT
5-021 MEDICAL MALPRACTICE: HOSPITAL
5-022 ASSISTED LIVING CENTER
5-023 DRAM SHOP LIABILITY
5-024 PRODUCTS LIABILITY
5-025 GEORGIA DOT/STATE TORT CLAIMS ACT
5-026 BAD FAITH/NEGLIGENT FAILURE TO SETTLE
5-027 CHECKLIST FOR COMPLAINTS
CHAPTER 6: FILING AND SERVICE OF THE COMPLAINT
6-000 FILING AND SERVICE OF THE COMPLAINT
6-001 SUMMONS
6-002 LETTER TO CLERK ENCLOSING COMPLAINT AND SERVICE ON DEFENDANT
6-003 LETTER TO CLERK ENCLOSING COMPLAINT AND RETURNING ORIGINAL FOR SERVICE
6-004 LETTER TO SHERIFF TO SERVE COMPLAINT
6-005 MOTION FOR APPOINTMENT OF PRIVATE PROCESS SERVER TO SERVE COMPLAINT
6-006 ORDER APPOINTING PRIVATE PROCESS SERVER
6-007 AFFIDAVIT OF SERVICE FOR PRIVATE PROCESS SERVER
6-008 LETTER TO PRIVATE PROCESS SERVER TO SERVE COMPLAINT AND DISCOVERY
6-009 LETTER TO SECRETARY OF STATE WITH COMPLAINT BY NON-RESIDENT MOTORIST STATUTE SERVICE
6-010 AFFIDAVIT OF COMPLIANCE FOR NON-RESIDENT MOTORIST STATUTE SERVICE
6-011 CERTIFIED LETTER TO DEFENDANT UNDER NON-RESIDENT MOTORIST STATUTE
6-012 ACKNOWLEDGMENT OF SERVICE
6-013 LETTER TO OPPOSING COUNSEL ENCLOSING ACKNOWLEDGMENT OF SERVICE FORM
6-014 MOTION FOR SUBSTITUTED SERVICE OF PROCESS BY PUBLICATION
6-015 AFFIDAVIT OF ATTORNEY SUPPORTING MOTION FOR SERVICE BY PUBLICATION
6-016 ORDER FOR SERVICE BY PUBLICATION
6-017 CERTIFIED LETTER TO INSURER ENCLOSING COPY OF COMPLAINT
6-018 CHECKLIST FOR FILING AND SERVICE OF THE COMPLAINT
CHAPTER 7: DISCOVERY: INTERROGATORIES, REQUEST FOR DOCUMENTS AND REQUEST FOR ADMISSIONS
7-000 DISCOVERY: INTERROGATORIES, REQUEST FOR DOCUMENTS AND REQUEST FOR ADMISSIONS
7-001 AUTO ACCIDENT
7-002 AUTO ACCIDENT: FAMILY PURPOSE
7-003 BOATING ACCIDENT DISCOVERY
7-004 TRUCKING COLLISION
7-005 PREMISES LIABILITY: FALL CASE
7-006 PREMISES LIABILITY: NEGLIGENT SECURITY
7-007 ESCALATOR/ELEVATOR ACCIDENT
7-008 DOG BITE
7-009 FALSE ARREST BY PREMISES OWNER
7-010 EMPLOYEE ASSAULT ON PREMISES
7-011 EMPLOYER LIABILITY
7-012 EXCESSIVE FORCE POLICE MISCONDUCT
7-013 MEDICAL MALPRACTICE: PHYSICIAN
7-014 MEDICAL MALPRACTICE: HOSPITAL
7-015 ASSISTED LIVING CENTER
7-016 DRAM SHOP LIABILITY
7-017 PRODUCTS LIABILITY
7-018 GEORGIA DOT/STATE TORT CLAIMS ACT
7-019 BAD FAITH/NEGLIGENT FAILURE TO SETTLE
7-020 JURISDICTION OVER THE DEFENDANT
7-021 UNDERINSURED/UNINSURED MOTORIST INSURER
7-022 DIRECT ACTION AGAINST TRUCK INSURER
7-023 NON-PARTY APPORTIONMENT OF FAULT DISCOVERY
7-024 LIABILITY OF EMPLOYER FOR EMPLOYEE’S CONDUCT
7-025 LIABILITY OF DEFENDANT FOR COLLISION
7-026 CERTIFICATE OF SERVICE OF DISCOVERY
7-027 CHECKLIST FOR INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS SERVED ON THE DEFENDANT
CHAPTER 8: ANSWERING DISCOVERY FROM THE DEFENDANT
8-000 ANSWERING DISCOVERY FROM THE DEFENDANT
8-001 LETTER TO CLIENT REQUESTING INFORMATION FOR DISCOVERY RESPONSES
8-002 LETTER TO OPPOSING COUNSEL CONFIRMING EXTENSION TIME TO RESPOND TO DISCOVER
8-003 RESPONSE TO INTERROGATORIES
8-004 VERIFICATION OF INTERROGATORY RESPONSES FOR CLIENT SIGNATURE
8-005 RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS
8-006 RESPONSE TO REQUEST FOR ADMISSIONS
8-007 SUPPLEMENTAL DISCOVERY RESPONSES
8-008 CHECKLIST FOR ANSWERING DISCOVERY FROM THE DEFENDANT
CHAPTER 9: COMPELLING RESPONSES TO DISCOVERY
9-000 COMPELLING RESPONSES TO DISCOVERY
9-001 LETTER TO OPPOSING COUNSEL REQUESTING OVERDUE DISCOVERY RESPONSES
9-002 LETTER TO OPPOSING COUNSEL REQUESTING COMPLETE DISCOVERY RESPONSES
9-003 GOOD FAITH LETTER TO OPPOSING COUNSEL UNDER RULE 6.4
9-004 MOTION TO COMPEL DISCOVERY RESPONSES
9-005 BRIEF IN SUPPORT OF MOTION TO COMPEL DISCOVERY RESPONSES
9-006 MOTION TO STRIKE DEFENDANT’S ANSWER FOR FAILING TO RESPOND TO DISCOVERY
9-007 BRIEF IN SUPPORT OF MOTION TO STRIKE DEFENDANT’S ANSWER FOR FAILING TO RESPOND TO DISCOVERY
9-008 MOTION TO COMPEL NON-PARTY TO PRODUCE DOCUMENTS
9-009 AFFIDAVIT IN SUPPORT OF MOTION TO COMPEL NON-PARTY
9-010 ORDER ON MOTION TO COMPEL NON-PARTY TO PRODUCE DOCUMENTS
9-011 LETTER TO OPPOSING COUNSEL REQUESTING VERIFICATION TO INTERROGATORY RESPONSES
9-012 CHECKLIST FOR COMPELLING RESPONSES TO DISCOVERY
CHAPTER 10: DEPOSITIONS
10-000 DEPOSITIONS
10-001 LETTER TO CLIENT CONFIRMING DEPOSITION
10-002 LETTER TO OPPOSING COUNSEL CONFIRMING DEPOSITION
10-003 NOTICE OF DEPOSITION OF WITNESS OR PARTY FOR DISCOVERY
10-004 NOTICE OF VIDEOTAPED DEPOSITION
10-005 LETTER TO DOCTOR CONFIRMING DEPOSITION
10-006 NOTICE OF EVIDENTIARY DOCTOR DEPOSITION
10-007 NOTICE OF EXPERT DEPOSITION FOR DISCOVERY
10-008 LETTER TO OPPOSING COUNSEL REQUESTING DEPOSITION OF CORPORATE REPRESENTATIVE
10-009 NOTICE OF CORPORATE REPRESENTATIVE DEPOSITION FOR DISCOVERY
10-010 NOTICE OF CORPORATE REPRESENTATIVE DEPOSITION ON FINANCIAL ISSUES
10-011 LETTER TO WITNESS ENCLOSING SUBPOENA FOR DEPOSITION
10-012 AMENDED DEPOSITION NOTICE
10-013 CHECKLIST FOR DEPOSITIONS
CHAPTER 11: OTHER DOCUMENTS RELATED TO DISCOVERY
11-000 OTHER DOCUMENTS RELATED TO DISCOVERY
11-001 CERTIFICATION OF BUSINESS RECORD
11-002 NOTICE OF INTENT TO INTRODUCE CERTIFIED COPY OF BUSINESS RECORDS
11-003 REQUEST FOR PRODUCTION OF DOCUMENTS TO NON-PARTY
11-004 REQUEST FOR CELLPHONE RECORDS
11-005 LETTER ENCLOSING SUBPOENA FOR DRIVING RECORD
11-006 JOINT MOTION TO EXTEND DISCOVERY PERIOD
11-007 ORDER EXTENDING DISCOVERY PERIOD
11-008 CONSENT SCHEDULING ORDER
11-009 CONSENT PROTECTIVE ORDER
11-010 CHECKLIST FOR OTHER DOCUMENTS RELATED TO DISCOVERY
CHAPTER 12: MOTIONS AND RESPONSES
12-000 MOTIONS AND RESPONSES
12-001 MOTION TO ADD PARTY DEFENDANT
12-002 BRIEF IN SUPPORT OF MOTION TO ADD PARTY DEFENDANT
12-003 MOTION FOR DEFAULT JUDGMENT
12-004 CERTIFICATE OF DEFAULT
12-005 ORDER ENTERING DEFAULT JUDGMENT
12-006 MOTION TO ENFORCE SETTLEMENT
12-007 CONSENT MOTION TO DISMISS LESS THAN ALL PARTIES
12-008 ORDER DISMISSING LESS THAN ALL PARTIES
12-009 MOTION FOR PARTIAL SUMMARY JUDGMENT ON LIABILITY OF NON-PARTY
12-010 BRIEF IN SUPPORT OF MOTION FOR PARTIAL SUMMARY JUDGMENT ON LIABILITY OF NON-PARTY
12-011 CONSENT MOTION FOR CONTINUANCE FROM TRIAL CALENDAR
12-012 BRIEF IN RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
12-013 RESPONSE TO DEFENDANT’S STATEMENT OF MATERIAL FACTS
12-014 PLAINTIFF’S STATEMENT OF MATERIAL FACTS TO WHICH THERE EXISTS A GENUINE ISSUE TO BE TRIED
12-015 THEORY OF RECOVERY
12-016 AFFIDAVIT OF WITNESS
12-017 NOTICE OF FILING ORIGINAL DISCOVERY
12-018 REQUEST TO FILE ORIGINAL DISCOVERY
12-019 NOTICE OF HEARING
12-020 STIPULATION EXTENDING TIME TO RESPOND TO MOTION
12-021 WITHDRAWAL OF MOTION
12-022 CHECKLIST FOR MOTIONS AND RESPONSES
CHAPTER 13: LITIGATION LETTERS
13-000 LITIGATION LETTERS
13-001 LETTER TO CLIENT ENCLOSING MEDICAL AUTHORIZATION FOR DEFENDANT
13-002 LETTER TO OPPOSING COUNSEL ENCLOSING MEDICAL AUTHORIZATION EXECUTED BY CLIENT
13-003 LETTER TO OPPOSING COUNSEL REQUESTING RECORDS OBTAINED FROM NON-PARTIES
13-004 LETTER TO CLIENT EXPLAINING INDEPENDENT MEDICAL EXAMINATION
13-005 LETTER TO EXPERT TO REVIEW RECORDS
13-006 LETTER TO WITNESS REQUESTING A RECORDED STATEMENT
13-007 LETTER TO JUDGE ENCLOSING PROPOSED ORDER
13-008 CHECKLIST FOR LITIGATION LETTERS
CHAPTER 14: TRIAL
14-000 TRIAL
14-001 LETTER TO CLERK STIPULATING CASE TO TRIAL CALENDAR
14-002 LETTER TO CLIENT CONFIRMING TRIAL DATE
14-003 LETTER TO WITNESS ENCLOSING SUBPOENA AND CONFIRMING TRIAL DATE
14-004 LETTER TO EXPERT CONFIRMING TRIAL DATE
14-005 CONSOLIDATED PRE-TRIAL ORDER
14-006 MOTIONS IN LIMINE
14-007 BRIEF IN SUPPORT OF MOTIONS IN LIMINE
14-008 LETTER TO OPPOSING COUNSEL ENCLOSING SUBPOENA OF PARTY
14-009 ORDER ALLOWING VIDEO EQUIPMENT INTO COURTROOM
14-010 REQUEST TO CHARGE
14-011 GENERAL VERDICT FORM
14-012 APPORTIONMENT LIABILITY VERDICT FORM
14-013 CHECKLIST FOR TRIAL
CHAPTER 15: SETTLEMENT AND RESOLUTION OF CLAIMS
15-000 SETTLEMENT AND RESOLUTION OF CLAIMS
15-001 COMPREHENSIVE DEMAND LETTER
15-002 UNLIQUIDATED DAMAGES DEMAND INTRODUCTION
15-003 UNDERINSURED MOTORIST COVERAGE DEMAND INTRODUCTION
15-004 POLICY LIMITS DEMAND INTRODUCTION
15-005 REQUEST FOR AFFIDAVIT OF NO ADDITIONAL INSURANCE DEMAND INTRODUCTION
15-006 AFFIDAVIT OF NO ADDITIONAL INSURANCE
15-007 OFFER OF SETTLEMENT
15-008 CERTIFICATE OF SERVICE OF OFFER OF SETTLEMENT
15-009 CONSENT JUDGMENT
15-010 ASSIGNMENT OF BAD FAITH CLAIM AGAINST INSURER
15-011 LETTER TO OPPOSING COUNSEL CONFIRMING MEDIATION
15-012 LETTER TO CLIENT EXPLAINING MEDIATION
15-013 LETTER TO OPPOSING COUNSEL CONFIRMING SETTLEMENT
15-014 W-9 Tax Identification Form
15-015 SETTLEMENT STATEMENT
15-016 LETTER TO HEALTH INSURER ABOUT POSSIBLE LIEN
15-017 LETTER TO WORKERS’ COMPENSATION CARRIER DENYING LIEN
15-018 LETTER TO MEDICARE INQUIRING ABOUT LIEN
15-019 Medicare Proof of Representation Form
15-020 LETTER TO MEDICAID INQUIRING ABOUT LIEN
15-021 LETTER TO LIENHOLDER ENCLOSING COMPROMISED PAYMENT OF LIEN
15-022 LETTER TO REFERRING ATTORNEY ENCLOSING FEE
15-023 CHECKLIST FOR SETTLEMENT AND RESOLUTION OF CLAIMS
CHAPTER 16: ADMINISTRATIVE FORMS
16-000 ADMINISTRATIVE FORMS
16-001 CHANGE OF ADDRESS
16-002 LEAVE OF ABSENCE
16-003 CONFLICT LETTER
16-004 LETTER TO CLIENT EXPLAINING POTENTIAL HEALTHCARE CLAIMS
16-005 LETTER TO CLIENT ASSERTING ATTORNEY LIEN
16-006 NOTICE TO DEFENDANT/INSURER OF ATTORNEY LIEN
16-007 LETTER TO CLIENT PROVIDING NOTICE OF WITHDRAWAL
16-008 NOTICE OF WITHDRAWAL
16-009 MOTION TO WITHDRAW AS COUNSEL
16-010 ORDER GRANTING MOTION TO WITHDRAW AS COUNSEL
16-011 NOTICE OF APPEARANCE OF COUNSEL
16-012 SUBSTITUTION OF COUNSEL
16-013 CHECKLIST FOR ADMINISTRATIVE FORMS
CHAPTER 17: FILING A FEDERAL LAWSUIT
17-000 INTRODUCTION TO FEDERAL FORMS
17-001 CHECKLIST FOR FEDERAL DIVERSITY FORMS
17-002 INTRODUCTION FOR FEDERAL DIVERSITY COMPLAINT
17-003 Federal Civil Cover Sheet
17-004 Federal Summons
17-005 CERTIFICATE OF INTERESTED PERSON
17-006 MOTION FOR REMAND
17-007 BRIEF IN SUPPORT OF MOTION FOR REMAND
CHAPTER 18: FEDERAL LITIGATION DOCUMENTS
18-001 JOINT PRELIMINARY PLANNING REPORT & DISCOVERY PLAN
18-002 INITIAL DISCLOSURES (NDGA)
18-003 SUPPLEMENT TO INITIAL DISCLOSURES
18-004 MOTION FOR LEAVE TO ADD CLAIMS
18-005 BRIEF IN SUPPORT OF MOTION FOR LEAVE TO ADD CLAIM
18-006 CERTIFICATE OF COMPLIANCE FOR FILING BRIEF
CHAPTER 19: DISCOVERY IN FEDERAL COURT
19-001 INTRODUCTION TO WRITTEN DISCOVERY
19-002 INTRODUCTION TO REQUEST TO ADMIT
19-003 DEPOSITION NOTICE FOR WITNESS
19-004 DEPOSITION NOTICE FOR CORPORATE REPRESENTATIVE
19-005 NOTICE OF VIDEOTAPED DEPOSITION
19-006 MOTION TO COMPEL DISCOVERY RESPONSES
19-007 BRIEF IN SUPPORT OF MOTION TO COMPEL DISCOVERY RESPONSES
19-008 MOTION TO STRIKE ANSWER
19-009 BRIEF IN SUPPORT OF MOTION TO STRIKE ANSWER
19-010 CERTIFICATE OF DISCOVERY
CHAPTER 20: EXPERTS IN FEDERAL COURT
20-001 IDENTIFICATION OF RETAINED EXPERT WITH RULE 26 REPORT
20-002 IDENTIFICATION OF TREATING PHYSICIAN AS EXPERT
20-003 DAUBERT MOTION TO EXCLUDE EXPERT TESTIMONY
20-004 BRIEF IN SUPPORT OF DAUBERT MOTION
20-005 BRIEF IN OPPOSITION TO DAUBERT MOTION
CHAPTER 21: FEDERAL TRIAL AND JUDGMENT
21-001 MOTION FOR DEFAULT JUDGMENT
21-002 CONSOLIDATED PRE-TRIAL ORDER
21-003 STIPULATION OF DISMISSAL
21-004 BRIEF IN RESPONSE TO MOTION FOR SUMMARY JUDGMENT
 
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