We’ve requested for production of documents which are in the possession of the defendants. We don't think that there'll be any dispute that the documents are relevant to the case, since they were, in fact, mentioned in the defendants' answer, alth ...   Read More

        We received yesterday an opposition (to our motion for production of documents) which argues that our motion should be denied because it was “nothing but a fishing expedition”. It says that we were just fishing beca ...   Read More

     I got such favorable results from using the modes of discovery in a civil case (it got settled almost immediately) that I resolved to use them more in future cases.      However, one case later made me realize that, unlike the judge in that ea ...   Read More

  Why is "stipulation of facts" becoming a useless exercise during preliminary conferences? I went through a preliminary conference last week and virtually got no stipulation from the other side. In fact, when I lamented the lack of cooperation from the other lawyers, I ...   Read More

      Is the use of a deposition a matter of right? After the answer to the complaint is served, yes it seems to be so, because, if we read Rule 23, deposition can be taken even without leave of court. Cases decided by the Supreme Court seem to say that, because there is ...   Read More

A judge in Pasig City commended a lawyer in our firm for serving written interrogatories on the defendants as soon as the answer to our complaint was filed. He said that he would like to see more lawyers using this tool (and the other modes of discovery) in preparing for cases. On the o ...   Read More

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