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A survey of discovery orders issued by courts around the Bay Area reveal some basic truths: Judges are busy, short on staff, and handling issues far more important than your discovery squabble, and lawyers of all vintages fall into basic discovery traps. If you are new to the litigation game and have never been to trial — it is hard to grasp just how little evidence is ultimately presented to the jury. It only makes sense. No juror is going to parse through the set of 100 interrogatories you took an entire weekend to craft. So how do you go about securing the evidence you need in an intelligent and thoughtful manner? Four words summarize the goal of discovery: Get to the point. Often, however, overzealous lawyers obscure this goal by serving an endless flood of discovery. This is nothing but a disservice to your client, your case and to the overwhelmed court staff who will end up reading about your discovery dispute.

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