...iver had already sent a demand letter. A month later, company counsel interviewed the same witnesses, wrote notes evaluating their credibility, and emailed the risk manager legal advice about settlement exposure. The wit...
Citations: Fed. R. Civ. P. 26(b)(3), Fed. R. Civ. P. 26(b)(5), Fed. R. Evid. 502, Hickman v. Taylor, Upjohn Co. v. United States
...ion, RefineryCo's outside litigation counsel hired an investigator to interview night-shift workers. The investigator obtained signed witness statements three days after the explosion. Counsel also wrote a memorandum sum...
Citations: Fed. R. Civ. P. 26(b)(3), Fed. R. Evid. 502
...d to human resources; and all notes prepared by company counsel after interviewing employees once litigation was threatened. The employer objected that the requests were overbroad, disproportionate, privileged, and undul...
Citations: Fed. R. Civ. P. 26(b)(1), Fed. R. Civ. P. 26(b)(5), Fed. R. Civ. P. 26(c), Fed. R. Civ. P. 34(b)
...letter threatening suit. The owner's lawyer hired an investigator to interview a security guard who saw the explosion. The investigator obtained a signed factual statement from the guard. Before discovery began, the gua...
Citations: Fed. R. Civ. P. 26(b)(3), Hickman v. Taylor
...ent agreement, her resume, GreenSteps's proposed job description, and interview notes. The agreement prohibits using confidential customer lists for one year, but it does not bar employment by a competitor. The interview...
Citations: NCBE MPT preparation materials, NCBE MPT overview
...he facts and cases, but has not typed any answer. The task memo asks for a letter to opposing counsel demanding payment and explaining why the client's claim is strong. The File includes a contract, invoices, emails admi...
Citations: NCBE MPT preparation materials, NCBE MPT overview
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