Develop a master plan for successful pretrial discovery with Pretrial Discovery: Strategy and Tactics. In this volume, you'll find cutting-edge guidance on such topics as: Protective orders to restrict opposing counsel's discovery Neutral or hostile witnesses Strategic planning Discovery tactics in the pleading stage Informal discovery Mandatory prediscovery disclosure Tactics for the deposing attorney Deposition tactics for the opposing attorney Interrogatories Production requests Physical and mental examinations Requests for admissions Discovery lawsuits Protective orders Sanctions Clients objectives and priorities Converting the discovery sequence into a timetable that the judge will approve This publication includes state discovery statutes, rules, and formbooks.