Triple-Threat Discovery Forms

by R. Rogge Dunn and Trey Cox

Knock Opposing Counsel Off Balance

Discovery provides the best opportunities for throwing punches that force opposing counsel to react rather than attack.

This 750-page book of forms provides you the power to dominate the early discovery rounds. Combining interrogatories, requests for admissions, and requests for production into one strategically-interwoven document, these powerful discovery documents will hit your opponents hard. You receive triple-threat discovery forms for these types of cases:

-- Slip and fall
-- Product liability
-- Wrongful death
-- Insurance coverage
-- Bad faith
-- Construction services
-- Sexual harassment
-- Sexual discrimination
-- Stealing trade secrets
-- Workers’ compensation retaliation
-- Age discrimination
-- Whistleblower

Litigation favors the quick and forceful attacker, yet limited time prevents many attorneys from striking aggressively at the outset. Staying on the offensive is a proven technique for achieving a strong settlement position. When you force your opponents to spend their limited time reacting to your moves, you keep them from advancing their cases. You buy yourself time to make your next moves, push your case forward, and stay on the attack.

To attack aggressively at the outset of discovery, begin with the pattern documents found in Rogge Dunn’s new Triple-Threat Discovery Forms. Focusing on employment, business, insurance, and personal injury cases, this collection creatively weaves together interrogatories, requests for admissions, and requests for production into a powerful first-strike discovery document.

59 Bonus Discovery Forms. Triple-Threat Discovery Forms also contains deposition outlines, model letters, pattern interview questions, intake questionnaires, and other discovery aids. For example:

Depositions
11 deposition outlines
Pointers for clients
Preparation of experts
Preparation of witnesses

Letters
Letter to corporate client re ways to maintain attorney/client privilege during client’s investigation
Doctor’s protection
Requesting doctor reduce lien
3 notices to preserve evidence

Plus
2 protective orders
3 pattern interviews
2 intake questionnaires
Interview of potential expert witness
Memo to paralegal re items needed for hearings and depositions
Agreement regarding production of documents for settlement purposes only
And many more

How Pre-Drafted Discovery Documents Help

  • Reduce drafting time. Whether you copy and paste selected questions from the free companion CD, dictate from the book, or customize whole forms, using pre-drafted questions and requests can save you hours.

  • Elicit more complete answers. The comprehensive definitions and clear, direct phrasing of the questions and requests will reduce the number of objections and non-responsive answers you receive.

  • Avoid omissions. The extensive documents in Triple-Threat Discovery Forms will bring to mind fertile topics for exploration, and the detailed pattern questions and requests will highlight the best areas of inquiry.

  • Produce quality work. By starting with questions and requests that have already been used and revised several times, your first draft will read like a polished final copy.

Updated annually.  ISBN 1-58012-101-2 Book price: $79.00

J7


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Related Titles:

Guerrilla Discovery
Handling Federal Discovery
How to Prepare for, Take and Use a Deposition
Model Interrogatories

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Updated 12/12/07 
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