By S.J. Walker
written discovery is a constant in all of litigation. The goal: to permit parties
to evaluate the case, identify issues, and prepare for depositions and trial.
Much of written discovery begins with form interrogatories and special
interrogatories. Unfortunately, novice lawyers, and possibly some seasoned
lawyers, forget that the defense counsel will use the information in your client’s
interrogatories at deposition and throughout the case. As such, making sure a
proper analysis is done on each question will ensure your client provides the
proper and accurate responses. It is the professional responsibility of the
lawyer to represent their client competently and diligently, ...