I had the opportunity tonight to work with a great group of high school kids from my area on a violence presentation for eighth grade students! It was so much fun, and those kids are truly talented and passionate about making changes in the world!
What bothered me was that these high school students looked at me like an alien when I brought up the need to educate about exploitation and trafficking of children. The average age of entry into prostitution is 12-13 years old according to a study by Shared Hope International (I believe). Aren't those our eighth graders? Why don't our high school seniors know their risk for this? I guess its my "hot topic" right now, and hopefully for longer, but I was shocked that they knew nothing about it. I guess, in retrospect, at 25, I didn't know anything about it either. The women that are victims of prostitution and commercial sexual exploitation are "damaged goods". The violence they face, including children recruited into the trade, is incomprehensible in the light of how our society views prostitutes.
I highly recommend you all check out Somebody's Daughter by Julian Sher. I recently read it, and it sheds a completely different light on the policies and laws in place to protect our children from being pimped out. It touches on each and every aspect of the trafficking industry that should disgust the average person.
This isn't just happening outside of our borders, its happening within. Hundreds of thousands of children are being bought and sold within our borders each year.
....and now its time for supper.
Wednesday, December 21, 2011
Educating Our Youth!
Saturday, December 17, 2011
Merry Christmas to Me!!!
Writing from my new iPad! I am so pumped to use tis thing for work and extra circulars! So far I've found FastCase to be an indispensable app. Does anyone have any other suggested apps? Keeping in mind I do bankruptcy and litigation, along with activism in the criminal realm (more policy and procedure and lobbying). I'd love to hear about your favorite iPad apps!
Monday, November 21, 2011
... and for a good laugh....
Jynx decided this weekend to get into the holiday spirit!
Here are a few photos from his photo shoot:
Here are a few photos from his photo shoot:
Extra Curricular Activities and Becoming (too) Inspired to Change the World
As my normal work has dwindled down to a slight sputter (whenever the mood strikes for work - not mine, theirs), I have had time and energy to put into my extra-curricular activities. As some of you may know, I took a volunteer training for my local Victim Services agency last spring, and have been working as a volunteer victim advocate on our local sexual assault crisis line for about six months now. I love love love helping these people. I can't describe the wonderful feeling that comes after a successful intervention.
Anyway, through my Victim Services training and meetings, I have gotten to know some great people. Two of the individuals I met, run an organization called Mission 21. Mission 21 is an anti-human trafficking organization focused on making survivors out of children entrapped in the sex trafficking industry. In addition, they make a point of educating the community on the signs, dangers, and all other aspects of the industry.
With that said, I am frustrated. M21's founders have been working with local government and courts to encourage that prostitutes arrested in our community, on their first offense, are treated as victims. We recently hit a large roadblock, in that the County Attorney's office has informed the organization that they are not on board with this type of treatment unless the defendant (prostitute) is willing to testify against her trafficker (pimp).
I have a hard time seeing the fair application of justice in this policy. A first time prostitution arrest in MN is classified as a Misdemeanor. Why would you not immediately offer a diversion program? Funding? funding is provided by the diversion program. Consequences for actions? The most is a 30 day jail stint, where the woman is not beaten and raped by her pimp - positive if you ask most.
I guess I'm on the search for advice and knowledge as I begin researching protocols throughout the country and world for dealing with victims of human trafficking. Our international laws essentially let the victim have a 45-90 day "cooling off" period before requiring her to decide if she will testify against her pimp. For domestic victims, at least here, they are not given any time to "cool off" or explore their options. It enrages me.
As I finish off for today, I would like to end with an awesome principle from Dale Carnigie's How to Win Friends and Influence People: I refuse to fret that God did not equally distribute intelligence.
I will just keep telling myself that, as I wade through local government to reach a fair and progressive result for the victims I advocate for.
Anyway, through my Victim Services training and meetings, I have gotten to know some great people. Two of the individuals I met, run an organization called Mission 21. Mission 21 is an anti-human trafficking organization focused on making survivors out of children entrapped in the sex trafficking industry. In addition, they make a point of educating the community on the signs, dangers, and all other aspects of the industry.
With that said, I am frustrated. M21's founders have been working with local government and courts to encourage that prostitutes arrested in our community, on their first offense, are treated as victims. We recently hit a large roadblock, in that the County Attorney's office has informed the organization that they are not on board with this type of treatment unless the defendant (prostitute) is willing to testify against her trafficker (pimp).
I have a hard time seeing the fair application of justice in this policy. A first time prostitution arrest in MN is classified as a Misdemeanor. Why would you not immediately offer a diversion program? Funding? funding is provided by the diversion program. Consequences for actions? The most is a 30 day jail stint, where the woman is not beaten and raped by her pimp - positive if you ask most.
I guess I'm on the search for advice and knowledge as I begin researching protocols throughout the country and world for dealing with victims of human trafficking. Our international laws essentially let the victim have a 45-90 day "cooling off" period before requiring her to decide if she will testify against her pimp. For domestic victims, at least here, they are not given any time to "cool off" or explore their options. It enrages me.
As I finish off for today, I would like to end with an awesome principle from Dale Carnigie's How to Win Friends and Influence People: I refuse to fret that God did not equally distribute intelligence.
I will just keep telling myself that, as I wade through local government to reach a fair and progressive result for the victims I advocate for.
Saturday, October 8, 2011
It's Been A While!
As I have become consumed in the preparation of a Bankruptcy Court trial, I have come to realize how exponentially important it is to utilize paralegals and their skills to their potential.
I work in a firm with a traditional view of the paralegal's role: a glorified secretary. However, along comes me and a massively complicated and messy exception from discharge case. I'm not going to gouge the details, but it involves a lot of bad record keeping and a mess of financial documents not well organized.
So, you ask, what is my role supposed to be by firm standards? Oh, you know, put together the exhibits the attorney asks for, make edits on the documents the attorney writes, and transcribe anything necessary. Yes, this is very much glorified secretarial work.
In retrospect, I realistically may have preferred that role to the role I took. I started by analyzing and creating spreadsheet summaries of all of the messy financial documents. Then, wrote a factual summary that will later be a part of the trial memorandum (in Bankruptcy Court this is kind of like the Attorney's opening statement). From the factual summary, I plugged in all of the documents and deposition testimony needed to support the allegations. Then, I've spent the last week in a war room with the attorney, on several conference calls, filling in holes - holes in the factual summary, holes in the attorneys' (yes, this includes opposing counsel) understanding of the facts, and holes in the testimony needed from our witnesses. I don't have a clue how many hours I've got into this file, but I know its basically an insurmountable number that the client may not be very happy about if they loose.
Now, I sit here, on this beautiful Saturday afternoon, reading through case law and answering e-mails while the attorney continues to work up the trial memorandum. On the plus side of this, I have been authorized to work from home and work overtime, so its all billable, and I get to enjoy the October record highs, fall breeze, and smell of freshly raked leaves (thanks to the boyfriend).
How does your firm treat its paralegals? What are some tips on coming into the 21st century when it comes to utilizing paralegals? If anybody has anything to share, I'd love to hear about it!
I work in a firm with a traditional view of the paralegal's role: a glorified secretary. However, along comes me and a massively complicated and messy exception from discharge case. I'm not going to gouge the details, but it involves a lot of bad record keeping and a mess of financial documents not well organized.
So, you ask, what is my role supposed to be by firm standards? Oh, you know, put together the exhibits the attorney asks for, make edits on the documents the attorney writes, and transcribe anything necessary. Yes, this is very much glorified secretarial work.
In retrospect, I realistically may have preferred that role to the role I took. I started by analyzing and creating spreadsheet summaries of all of the messy financial documents. Then, wrote a factual summary that will later be a part of the trial memorandum (in Bankruptcy Court this is kind of like the Attorney's opening statement). From the factual summary, I plugged in all of the documents and deposition testimony needed to support the allegations. Then, I've spent the last week in a war room with the attorney, on several conference calls, filling in holes - holes in the factual summary, holes in the attorneys' (yes, this includes opposing counsel) understanding of the facts, and holes in the testimony needed from our witnesses. I don't have a clue how many hours I've got into this file, but I know its basically an insurmountable number that the client may not be very happy about if they loose.
Now, I sit here, on this beautiful Saturday afternoon, reading through case law and answering e-mails while the attorney continues to work up the trial memorandum. On the plus side of this, I have been authorized to work from home and work overtime, so its all billable, and I get to enjoy the October record highs, fall breeze, and smell of freshly raked leaves (thanks to the boyfriend).
How does your firm treat its paralegals? What are some tips on coming into the 21st century when it comes to utilizing paralegals? If anybody has anything to share, I'd love to hear about it!
Wednesday, September 14, 2011
Minnesota Paralegal Association - Citations
I have been writing a few small articles for the MPA's monthly newsletter "Citations", since my fabulous co-worker Gena began editing the newsletter last spring. I have switched gears in my articles from funny celebrity legal stories in the news, to sharing the blogging world with the association. If you are reading my blog, and would like to be featured, please shoot me an e-mail at: marenjoyce@hotmail.com . Please indicate if the MPA has permission to republish any of your blog posts, or if you are extra proud of one special post, please forward that along, and it may be published.
Thanks all for reading! I will come back with an update at life in the trenches when I get a few spare minutes (its been crazy around here!).
Thanks all for reading! I will come back with an update at life in the trenches when I get a few spare minutes (its been crazy around here!).
Monday, August 29, 2011
OneNote is Ah-mah-zing!
Aha! The days of creating the dreaded trial notebook-three-ring-binder-tabbed-out-too-many-documents-and-crap-to-deal-with is officially behind me!
There's a trial on Sept. 19th and there's a mess of financial statements and checks and other garbage to go along with it. Me, being brilliant (not only self proclaimed, but third-party proclaimed as well), started a notebook in OneNote, and it is going to be perfect for bankruptcy court. Not only does the court only use electronic evidence anyway, now the attorney will have all of the electric evidence, notes, research, charts, spreadsheets, financial statements, and other junk on the computer screen.
OneNote allows you to create, basically, a giant three ring binder. You create the notebook, you create tabs in the notebook, you create tabs on the tabs of the notebook, and then you can create outer tab "groups". You can print anything to OneNote, including .pdf, websites, word documents, etc. Spreadsheets fit nicely onto the pages, and best of all, you can insert little notes to yourself or others anywhere on any page. Word up, this is awesome!
Now, I may be behind on technological advances, my office has had OneNote since January, and I just last week figured out how to use it. However, now rather than spending my Wisconsin vacation bulking up for the paralegal-ish duty of hauling boxes and boxes and boxes of paper copies into the courthouse, I will be enjoying me some adult beverages and the hotel's hot tub. This is my way of avoiding the dreaded burnout.
There's a trial on Sept. 19th and there's a mess of financial statements and checks and other garbage to go along with it. Me, being brilliant (not only self proclaimed, but third-party proclaimed as well), started a notebook in OneNote, and it is going to be perfect for bankruptcy court. Not only does the court only use electronic evidence anyway, now the attorney will have all of the electric evidence, notes, research, charts, spreadsheets, financial statements, and other junk on the computer screen.
OneNote allows you to create, basically, a giant three ring binder. You create the notebook, you create tabs in the notebook, you create tabs on the tabs of the notebook, and then you can create outer tab "groups". You can print anything to OneNote, including .pdf, websites, word documents, etc. Spreadsheets fit nicely onto the pages, and best of all, you can insert little notes to yourself or others anywhere on any page. Word up, this is awesome!
Now, I may be behind on technological advances, my office has had OneNote since January, and I just last week figured out how to use it. However, now rather than spending my Wisconsin vacation bulking up for the paralegal-ish duty of hauling boxes and boxes and boxes of paper copies into the courthouse, I will be enjoying me some adult beverages and the hotel's hot tub. This is my way of avoiding the dreaded burnout.
I'm Recommended Reading This Week!
:) :) http://www.practicalparalegalism.com/2011/08/practical-paralegalisms-recommended_28.html
I can't believe my foolishness got me recognition! Or maybe I can, because I solved the problem, which is what us paralegals do!
I can't believe my foolishness got me recognition! Or maybe I can, because I solved the problem, which is what us paralegals do!
Friday, August 19, 2011
Whoops.
If its one thing I've learned in my short paralegal career, its that when you make a mistake, you can almost always fix it. That being said, I almost had a heart attack Monday morning when I learned the Reply Brief sent out Friday for filing with the MN Court of Appeals was filed a day late!
A day late. My rookie mistake. I could blame a lack of training or guidance, but I can't, I neglected to read the rule. Plain and simple, I made a big f'up.
Monday morning, I had a call from the Appellate Court clerk informing me the attorney needed to file a Motion to Accept Late Filing. Great. I tell him, I tell him not to be too mad at me, and draft a motion; this time reading the rules.
Needless to say, the extension was approved. I still feel bad, as the attorney called it his own "rookie mistake", taking the blame, and blemish on his reputation. However, I have learned my lesson, have someone who knows what the hell they're doing double check the docketing if I'm not sure.
With that being said, most mistakes in the legal world can be corrected. Often times, in Bankruptcy Court (which is where most of my work is), it is a simple e-mail to the Judge's clerk. The clerks have been there, and they are usually willing to work with you. Court clerks should be your best friend as a paralegal, they are almost always willing to help you do it right, because they don't want to fix every time you do it wrong. So, ask them if you are unsure of a filing, deadline, or document format. Remember, they can't give legal advice (just like a paralegal), but they can help procedurally.
Also, if you do make the big f'up, like I did, work your ass off to correct it. Remember, correcting your mistakes is not billable time, and the attorney's work on the project should be limited as much as possible. Of course, they still need to know what is going on and are responsible for the final product, but they're not going to be happy loosing revenue while fixing your mistake.
Finally, remember, the attorneys do carry malpractice insurance, but they still have large deductibles and a law license to worry about.
In summary, be aware of preventing mistakes, the effect of those mistakes, and that you will need to fix those mistakes. We are all human, and it will happen to everyone at some point (thanks to my co-workers for reminding me of that on Monday when I was a total wreck). Life goes on, so don't beat yourself up.
A day late. My rookie mistake. I could blame a lack of training or guidance, but I can't, I neglected to read the rule. Plain and simple, I made a big f'up.
Monday morning, I had a call from the Appellate Court clerk informing me the attorney needed to file a Motion to Accept Late Filing. Great. I tell him, I tell him not to be too mad at me, and draft a motion; this time reading the rules.
Needless to say, the extension was approved. I still feel bad, as the attorney called it his own "rookie mistake", taking the blame, and blemish on his reputation. However, I have learned my lesson, have someone who knows what the hell they're doing double check the docketing if I'm not sure.
With that being said, most mistakes in the legal world can be corrected. Often times, in Bankruptcy Court (which is where most of my work is), it is a simple e-mail to the Judge's clerk. The clerks have been there, and they are usually willing to work with you. Court clerks should be your best friend as a paralegal, they are almost always willing to help you do it right, because they don't want to fix every time you do it wrong. So, ask them if you are unsure of a filing, deadline, or document format. Remember, they can't give legal advice (just like a paralegal), but they can help procedurally.
Also, if you do make the big f'up, like I did, work your ass off to correct it. Remember, correcting your mistakes is not billable time, and the attorney's work on the project should be limited as much as possible. Of course, they still need to know what is going on and are responsible for the final product, but they're not going to be happy loosing revenue while fixing your mistake.
Finally, remember, the attorneys do carry malpractice insurance, but they still have large deductibles and a law license to worry about.
In summary, be aware of preventing mistakes, the effect of those mistakes, and that you will need to fix those mistakes. We are all human, and it will happen to everyone at some point (thanks to my co-workers for reminding me of that on Monday when I was a total wreck). Life goes on, so don't beat yourself up.
Tuesday, August 9, 2011
A little respect if you may...
So, I don't plan to spend a lot of time on this blog complaining about my personal life, BUT since this is "law" related, I wanted to share.
Back in January, my ex-boyfriend "Ken" was arrested for violating the OFP I have against him. "Ken" is schizophrenic, and was off his medication. He had called and talked about women being chopped up and other nonsensicle things. I called OCSD because I was worried this man had completely lost his marbles. Sounds like I was right.
I was impressed with OCSD and RPD's efforts to find and arrest Ken that night. Since, Ken has been in custody - first in jail and then in a mental health facility.
Now, I need to remind you that I am a victim of a felony violation of OFP.
Yesterday, I looked at the Court's docket and to my surprise, the County Attorney dismissed the charge under Rule 30.01 - in other words, it was dismissed in the "interests of justice". I remembered back to a few weeks ago when I had a call from a victim/witness coordinator with the County Attorney's office, which I returned with a voice message, and was never called back.
Today, I started by calling the victim/witness coordinator again. Voice mail. I left another, with a reminder that she didn't return my call two and a half weeks ago, and I wanted to know why this case was dismissed. I gave her the entire morning, and she never called back.
After lunch, I called my victim advocate at the Women's Shelter. She was in the process of writing me a letter to let me know the charge had been dismissed, but again, didn't know why. She suggested I call the Assistant County Attorney assigned to the case....
I call the main number for the County Attorney's office, because direct lines are not listed on the web. The receptionist refuses to put me to the voice mail of the ACA, and instead sends me back to the voice mail of the victim/witness coordinator!!!
I then called and left a message with my contact at Victim Services, I'm hoping she can give me some answers, at least I know she will call me back. I also sent a strongly worded e-mail to the victim/witness coordinators' general e-mail box, suggesting I may just retain my own attorney (me? retain a lawyer? hahahaha!).
So, that is that. It is frustrating being a victim in Olmsted County's system. I had better luck with services in Ramsey county, which is known to be the most-behind-the-times county there is. I'll keep you all posted if I actually get any information. I assume that the charge was dropped due to incapacity. However, when they sent him for mental health evaluation, I was told they would seek Civil Commitment, in the alternative, if they were unable to proceed with the criminal charge.
UPDATE:: I got a call back the next morning from the CA's office. Apparently, my threat of hiring my own attorney got their attention. Anyway, they have "Ken" civilly committed and medicated. Hopefully it lasts. The Women's Shelter also sent me a cute letter saying the case was "dismissed" with a copy of the court docket. Perfecto, that really explains things.
Back in January, my ex-boyfriend "Ken" was arrested for violating the OFP I have against him. "Ken" is schizophrenic, and was off his medication. He had called and talked about women being chopped up and other nonsensicle things. I called OCSD because I was worried this man had completely lost his marbles. Sounds like I was right.
I was impressed with OCSD and RPD's efforts to find and arrest Ken that night. Since, Ken has been in custody - first in jail and then in a mental health facility.
Now, I need to remind you that I am a victim of a felony violation of OFP.
Yesterday, I looked at the Court's docket and to my surprise, the County Attorney dismissed the charge under Rule 30.01 - in other words, it was dismissed in the "interests of justice". I remembered back to a few weeks ago when I had a call from a victim/witness coordinator with the County Attorney's office, which I returned with a voice message, and was never called back.
Today, I started by calling the victim/witness coordinator again. Voice mail. I left another, with a reminder that she didn't return my call two and a half weeks ago, and I wanted to know why this case was dismissed. I gave her the entire morning, and she never called back.
After lunch, I called my victim advocate at the Women's Shelter. She was in the process of writing me a letter to let me know the charge had been dismissed, but again, didn't know why. She suggested I call the Assistant County Attorney assigned to the case....
I call the main number for the County Attorney's office, because direct lines are not listed on the web. The receptionist refuses to put me to the voice mail of the ACA, and instead sends me back to the voice mail of the victim/witness coordinator!!!
I then called and left a message with my contact at Victim Services, I'm hoping she can give me some answers, at least I know she will call me back. I also sent a strongly worded e-mail to the victim/witness coordinators' general e-mail box, suggesting I may just retain my own attorney (me? retain a lawyer? hahahaha!).
So, that is that. It is frustrating being a victim in Olmsted County's system. I had better luck with services in Ramsey county, which is known to be the most-behind-the-times county there is. I'll keep you all posted if I actually get any information. I assume that the charge was dropped due to incapacity. However, when they sent him for mental health evaluation, I was told they would seek Civil Commitment, in the alternative, if they were unable to proceed with the criminal charge.
UPDATE:: I got a call back the next morning from the CA's office. Apparently, my threat of hiring my own attorney got their attention. Anyway, they have "Ken" civilly committed and medicated. Hopefully it lasts. The Women's Shelter also sent me a cute letter saying the case was "dismissed" with a copy of the court docket. Perfecto, that really explains things.
Monday, August 8, 2011
Insomnia
GeoTagged, [N43.86052, E92.47949]
My insomnia has magically reappeared! Back to Tylenol pm I go!
So, here I am at home, redlining a depo summary.
On the amusing side.... I've attached a photo of Jynx with the remnants of the paper bag he attacked!
Sunday, August 7, 2011
How to Volunteer.
Nothing will look better on your resume than giving back to your community. NOTHING. Promise. Rochester has a LARGE number of unemployed paralegals, thanks to the factory over at the Minnesota School of Business. What MSB forgets to tell their students is that experience is everything, and the only way to pick up that experience is to volunteer. Yes, work for no pay.
A few ideas for you are:
(1) Take the Victim Service's crisis line training this fall. Work the crisis line, and learn about a whole other aspect of the criminal justice system!
(2) Volunteer with the Landlord-Tenant Hotline.
(3) File clerk with the Third District Public Defenders' Office.
(4) Get creative - call local firms, organizations, or county agencies and ASK if they need help. Most businesses and agencies are still recovering from the recession and are understaffed and overworked. Use your cahones and pick up the phone.
I understand the whole children, work, etc. excuses, BUT - if you want to stay in Rochester and work as a paralegal, put the excuses away - they're like assholes, everyone has one. Suck it up and get involved with your community.
A few ideas for you are:
(1) Take the Victim Service's crisis line training this fall. Work the crisis line, and learn about a whole other aspect of the criminal justice system!
(2) Volunteer with the Landlord-Tenant Hotline.
(3) File clerk with the Third District Public Defenders' Office.
(4) Get creative - call local firms, organizations, or county agencies and ASK if they need help. Most businesses and agencies are still recovering from the recession and are understaffed and overworked. Use your cahones and pick up the phone.
I understand the whole children, work, etc. excuses, BUT - if you want to stay in Rochester and work as a paralegal, put the excuses away - they're like assholes, everyone has one. Suck it up and get involved with your community.
Interesting Article on Sex Assault and Domestic Assault Victims
As you may or may not know, I am a volunteer sexual assault advocate with Victim Services, and am a domestic assault victim. This article talks about how the justice system treats victims.
http://lauramcwilliams.files.wordpress.com/2011/08/justice-from-victims-perspective2.pdf
http://lauramcwilliams.files.wordpress.com/2011/08/justice-from-victims-perspective2.pdf
Google for Instructions Next Time.
I made the biggest rookie mistake last week....
"Hey, summarize that huge, full of farmer speak deposition for me, would ya?"
... and so I begin. Writing a summary of what is contained within the 230 page deposition. After the first day and a half, I decide Google might be resourceful, you know, to confirm I was on the right track. Wrong. So wrong. You need citations to the deposition contained within the deposition summary, something I forgot. Whoops.
So, I paid myself back by spending the rest of the week re-writing farmer speak into coherent, factual sentences. ... and my weekend, redlining the stupid thing for no pay!
Lesson learned. Google for instructions next time.
"Hey, summarize that huge, full of farmer speak deposition for me, would ya?"
... and so I begin. Writing a summary of what is contained within the 230 page deposition. After the first day and a half, I decide Google might be resourceful, you know, to confirm I was on the right track. Wrong. So wrong. You need citations to the deposition contained within the deposition summary, something I forgot. Whoops.
So, I paid myself back by spending the rest of the week re-writing farmer speak into coherent, factual sentences. ... and my weekend, redlining the stupid thing for no pay!
Lesson learned. Google for instructions next time.
Monday, April 18, 2011
Interesting Note on Notarizing (in MN)
The individual you are notarizing need not sign in front of you. However, they must appear in person before you and attest to their signature. Didn't know that until the issue came up today. Just wanted to share!
Friday, April 15, 2011
Discovering Discovery
I'm starting this blog to share some tips, tricks, stories, and insights from my job as a bankruptcy paralegal. Specifically, I work with chapter 7 bankruptcy trustees and two associate attorneys in bankruptcy, creditor, and other various litigation.
April 20th will be my one year anniversary in my position. I've learned a ton in the last year, but the one thing I've struggled the most with has been drafting discovery requests.
This week, I had a shortened deadline (due to an attorney vacation) to get out discovery requests in an exception to discharge bankruptcy adversary proceeding. I needed to draft: requests for admissions, interrogs, and requests for production.
The exception to discharge was based on falsified or erroneous financial statements provided to the lender on an agricultural line of credit. So where did I start? - I started with the false financial statements. Using the statements, I created a line of questioning relating to each claimed asset - including disposition of the asset, and created admissions centered around the sworn financial statements.
Ultimately, the associate attorney on the file and I sat down with one of the partners, he reviewed, and they were looking good. He taught me the most important part of drafting discovery requests - how to get to your questions.
Focus on your objective. What is the ultimate goal of the action? Then, look to the law. What elements do I need to meet? Review the facts for missing information. What am I missing to meet the elements on a factual basis? Finally, formulate your questions to obtain the missing information.
I wish I could elaborate more, but its time to unwind my tightly spun brain :)
Subscribe to:
Posts (Atom)