Articles From Jo Anna Pollock

Operating under the amended Federal Rules 16 and 26 of Civil Procedure: A plaintiff’s lawyer’s perspective By Jo Anna Pollock Federal Civil Practice, September 2016 While the Federal Rules were amended to address discovery practice, the amendments are not as one-sided as they appear at first blush. Preparation coupled with reasonableness in your approach will net you the discovery that you need. 
The summary judgment motion—The strategic decisions you need to make By Jo Anna Pollock Federal Civil Practice, February 2016 Summary judgment motions are paper trials and, as such, several strategic decisions need to be made before you decide whether to file the motion or how to oppose one.
Off the record: Guidelines for deposition breaks By JoAnna Pollock Federal Civil Practice, April 2015 Concerns about witness coaching and deposition break schedules have recently made their way to the courts.
Update on expert practice: Expert discovery By Jo Anna Pollock Federal Civil Practice, December 2013 Save the date for "Experts Exposed: Expert Practice in Federal Court from A to Z," which will take place on February 21, 2014. 
What’s “plausible” in the post-Twombly and Iqbal world? A review of recent Seventh Circuit decisions By Jo Anna Pollock Federal Civil Practice, March 2013 A review of recent Seventh Circuit cases that have interpreted Twombly and Iqbal, and a look at how both plaintiffs and defendants should characterize a plaintiff’s complaint when arguing whether a plaintiff failed to state a claim pursuant to Federal Rules of Civil Procedure, Rule 12(b)(6).

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