Deposition Subpoena Is Valid Even Though Not Accompanied by an Executed Affidavit or Declaration
Discovery Sanctions Are Only for Past Costs Incurred, Regardless of Egregious Misconduct
Keeping Discovery Within the Scope of a Forum Non Conveniens Motion
Does Section 473 Include an In-House Counsel Who Is Also a Corporate Officer?
Failure to Comply With Discovery May Cost More Than Just Sanctions
Attorney Work-Product Privilege Does Not Extend to Written and Recorded Witness Statements, Including Those Taken by Counsel
Privileged Means Privileged