Table of Content 
- Chapter One: Planning for Discovery Chapter One: Planning for Discovery
- Chapter Two: Initial Disclosures
- Chapter Three: Interrogatories
- Chapter Four: Answers to Interrogatories
- Chapter Five: Document Requests
- Chapter Six: eDiscovery
- Chapter Seven: Answers to Document Requests
- Chapter Eight: Motion to Compel Production
- Chapter Nine: Expert Witness Disclosure
- Chapter Ten: Depositions of Fact and Expert Witnesses
- Chapter Eleven: Requests for Admission
- Chapter Twelve: Answers to Requests for Admission
- Chapter Thirteen: Motion in Limine
- Chapter Fourteen: Settlement
- Appendix
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