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Nobody Likes Motions to Compel:

 Plaintiff attorneys don’t like them because they aren’t paid an hourly fee to draft them; Defense attorneys don’t like them because they know how effective these motions are at slicing through their procedural gamesmanship; and Judges don’t like them because these motions take up valuable court time with juvenile spats…

I’m still amazed when defense attorneys direct their clients not to answer my questions during a deposition where no privilege exists. In other words, the defense attorney simply assumes the role of judge and decides what questions their client will and will not answer. Of course, the defense attorney instructs their client not to answer…