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Paper Mache, Origami & Other Creative Things To Do With Paper: The Art Of Paper Discovery In Texas

Updated: Sep 23

an origami boat made of pink paper in front of brown paper origami boats on blue paper

Strategies for Paper Discovery in Texas Litigation

This paper offers an in-depth exploration of the innovative strategies and best practices in the art of discovery within Texas litigation, presented by Paul N. Gold. It discusses the foundational steps of formulating an effective discovery strategy, the significance of precise pleadings, and tactical considerations that can influence the scope and outcome of discovery. The content is particularly valuable for litigation attorneys looking to refine their approach to gathering and presenting case-critical information.


Through detailed analysis, the paper provides a step-by-step guide on managing the discovery process, from initial interrogatories to the handling of requests for production and admissions. It emphasizes the legal nuances and strategic decisions that can significantly impact the effectiveness of discovery in legal battles. By integrating theoretical knowledge with practical applications, this paper serves as a comprehensive resource for attorneys aiming to leverage discovery to their advantage in litigation.

KEY TAKEAWAYS

  • Strategic Formulation: The importance of aligning discovery strategies with pleadings to ensure coherence and effectiveness in gathering necessary evidence.

  • Preservation and Representation: The critical role of representation/preservation letters in safeguarding potential evidence and defining the scope of discovery.

  • Pleadings and Discovery Alignment: How pleadings directly influence the scope and focus of discovery efforts, requiring strategic alignment.

  • Interrogatories and Depositions: Insights on the strategic use of interrogatories and depositions to uncover crucial case details without revealing too much strategic intent.

  • Practical Techniques: Practical advice on managing objections and motions that arise during the discovery process, ensuring compliance and protection of client interests.


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