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Start by reviewing all of the motions, briefs, discovery responses, and pleadings. Extract any dates that you come across during that review and put them into a chronology. As you’re doing your review, create a master to-do list for that case where you can keep notes about the things that you come across.
“Professed technological incompetence is not an excuse for discovery misconduct” is not a court holding you want to see (James v. For example, the bar exam can ask examinees to create documents with specific margins, page numbers, and styles, like the formats expected from local court rules. CV 8931-VCL, 2014 WL 6845560 (Del.
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