|Principles Particularly Applicable to Litigation
- We will not use any form of discovery or discovery scheduling for harassment, unjustified delay, to increase litigation expenses, or any other improper purpose.
- We will make good faith efforts to resolve by agreement any disputes with respect to matters contained in pleadings and discovery requests and objections.
- We will not engage in any conduct during a deposition that would not be appropriate if a judge were present. Accordingly, we will not obstruct questioning during a deposition or object to deposition questions, unless permitted by the applicable rules to preserve an objection or privilege and we will ask only those questions we reasonably believe are appropriate in discovery under the applicable rules.
- We will carefully craft document production requests so they are limited to those documents we reasonably believe are appropriate under the applicable rules. We will not design production requests for the purpose of placing an undue burden or expense on a party.
- We will respond to document requests reasonably. We will not interpret the request in an artificially restrictive manner to avoid disclosure of relevant and non-privileged documents. We will not produce documents in a manner designed to hide or obscure the existence of particular documents.
- We will carefully craft interrogatories so they are limited to those matters we reasonably believe are appropriate under the applicable rules, and we will not design them for the purpose of placing an undue burden or expense on a party.
- We will respond to interrogatories reasonably. We will not interpret interrogatories in an artificially restrictive manner to avoid disclosure of relevant and non-privileged information.
- We will base our discovery objections on a good faith belief in their merit. We will not object solely for the purpose of withholding or delaying the disclosure of properly discoverable information.
- During discovery, we will not engage in acrimonious
conversations or exchanges with opposing counsel, parties, or witnesses. We will advise our clients to conduct themselves in accordance with these provisions. We will not engage in undignified or discourteous conduct which degrades the legal proceeding.