How many times have you had to brief a motion for protective order filed by a defendant arguing that the defendant must not be deposed until after the plaintiff? And how many times have you had to wait for the defense disclosure of an expert because the defense claims that an expert cannot be disclosed until all plaintiff’s experts and all fact witnesses have been deposed? And how many times has discovery been substantially delayed and a trial postponed because plaintiff’s counsel or the court has acquiesced in these arguments?
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