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1. When must an answer be By 10:00 am on Monday after 9. What can an attorney do to 1. File a MOTION TO
filed to avoid default the expiration of 20 days from when the client is served with QUASH, or a protective
judgment? the date of service of the citation a deposition request without order.
and petition. the attorney's knowledge,
2/08, 7/08 and the attorney can't 2. If filed by the 3rd
attend? business day after service of
2. Under the General Venue 1. Where all or a substantial part
notices of deposition,
Statute Where is Venue of the events occurred
7/08, 7/10 deposition is stayed until
Proper? 2. Where the DEFENDANT
motion can be determined
RESIDES.
7/08, 7/10, 7/11 3. Where the corporate 10. During a deposition, what 1. "Objection, LEADING"
defendant has its PRINCIPAL objections are allowed? 2. "Objection, FORM"
PLACE OF BUSINESS. What if the other attorney 3. "Objection, NON-
makes other objections? RESPONSIVE"
3. How do you object to 1. File a MOTION TO
venue? When? TRANSFER VENUE alleging the
7/08 Argue that the opposing
factual and legal basis for the
counsel's objections are
2/08, 7/08, 7/10 transfer.
improper. Judge should
suspend the deposition and
2. Per due order of pleading in
move for sanctions.
Texas, motion must be filed
PRIOR TO or CONCURRENT 11. What does a respondent do if 1. File a traditional
WITH all OTHER PLEADINGS they believe there is no merit MOTION FOR SUMMARY
or motions. for the lawsuit against them? JUDGMENT and argue
there is no GENUINE
4. 5 Things in a Request for 1. Correct party names
7/08, 7/11 ISSUE OF MATERIAL
Disclosure 2. Damages
FACT.
3. Fact Witnesses
7/08 4. Retained testifying experts.
2. FILE A NO EVIDENCE
5. Medical records.
MOTION FOR SUMMARY
5. When must a response 1. Within 30 days from the date JUDGMENT and argue
denying a discovery of service. that the plaintiff has
request be filed? 2. After 30 days, it is deemed offered no evidence to
admitted without the necessity of support his claim.
7/08 a court order.
12. What is the response to a 1. Object to the summary
6. How is a discovery File a MOTION TO Motion for Summary judgment.
admission withdrawn WITHDRAW the deemed Judgment? When? 2. Present the ___
when it was admitted admission showing (evidence) showing that s a
because you didn't 1. good cause for the untimely 2/08, 7/08 GENUINE ISSUE OF
respond in time? filing of the response, and MATERIAL FACT exists.
2. that the withdrawal will not 3. Response should be filed
7/08 unduly prejudice Peter. NO LATER THAN SEVEN
7. What do you do when the File a MOTION TO COMPEL, as DAYS PRIOR TO THE
opposing party objects to allowed under the rules of HEARING.
your discovery request or discovery.
doesn't comply fully?