News & Events

Yarborough Applegate Attorneys Liam Duffy and John Dodds Publish Book, Dealing with Objections to Written Discovery

Posted: January 24, 2024

South Carolina trial lawyers navigating written discovery disputes in civil litigation now have a valuable new resource at their fingertips with the release of a book dedicated to the very topic, researched and written by Yarborough Applegate’s own Liam Duffy and John Dodds.

Dealing with Objections to Written Discovery: The Modern Approach to Discovery Objections in South Carolina State & Federal Courts is a 234-page compendium of hundreds of South Carolina federal and state authorities, including dozens of trial court orders, addressing the issue of written discovery obstruction. It features a robust section on sanctions for written discovery abuse and nearly 80 pages of discussion and research on common areas that tend to draw improper objections and spawn discovery disputes, including Requests for Confidentiality, Discovery of Financial Information, Other Similar Incident (“OSI”) discovery, and more. Readers will also find sample templates for a meet-and-confer letter, motion to compel, and memorandum in support.

Duffy and Dodds hope the first-of-its-kind release will continue to educate the state Bar and Judiciary on the impropriety of written discovery obstruction and gamesmanship by providing a picture of the judicial landscape on those issues across the state. Additionally, it will serve as centralized, formatted consolidation of the work of many other lawyers who have litigated these issues before, thus saving attorney time by not having to “reinvent the wheel.” 

“We hope this book will serve as a useful tool that helps time-pressed attorneys draft better Rule 11 letters, motions to compel, and well-researched memoranda on a number of common discovery issues, so that we as a profession can continue to ‘tame the discovery beast,’ as United States District Judge Joseph F. Anderson once wrote,” says Dodds.

Dealing with Objections to Written Discovery is available in both hard copy and e-book. Click here to order yours today.

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