The Litigation Manual: Pretrial

2d Cir 9th Cir action admissible adversary agree agreement amended answer arbitration argument attorney-client privilege avoid Civil Procedure claim client complaint confidential conflict Corp corporate criminal cross-examination defendant defendant's defense counsel deponent deponent's deposed deposition disclosure discovery dispute district court diversity jurisdiction docu documents employees engagement letter ethical evidence examiner example expert facts federal court Federal Rules fees firm important injunction interrogatories interview involved issues judge jurisdiction jury lawsuit lawyer letter rogatory limited litigation material matter ment Model Rule motion motion to compel negotiations ness objections opponent opposing counsel party perjury person plaintiff preparation privilege problem protective order questions reason relevant request requires response Rules of Civil sanctions seeking settle settlement settlement conference side's subpoena summary judgment Supp testify testimony tion tort tortfeasor transcript trial usually waiver withdraw witness witness's