In this blog I have asked that lawyers write in if there was a topic they would like me to address.  I have received many requests over the years and the next couple of blogs will be responding to some of these requests.  Here is the first one.

“I noticed a few things regarding privilege logs. 1) litigators are not sending them. 2) my opposing counsel tends to argue that there is no obligation to prepare a privilege log unless it is demanded by the requesting party and I don’t think that’s right – I think it’s an affirmative duty arising when someone withholds documents under an objection – is that right?”


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When plaintiff receives a demand for a physical examination he or she have 20 days after the service of the demand to serve their response. More likely than not, plaintiff counsel is going to allow the plaintiff to submit to the independent medical examination. If so, then there are a few things plaintiff counsel should be aware of.
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