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88 Def. Counsel J. 1 (2021)

handle is hein.journals/defcon88 and id is 1 raw text is: Advanced Topics in Oral Civil Discovery By: Robert F. Redmond, Jr. Bob Redmond is a partner at McGuire Woods in Richmond, Virginia. He focuses his practice on mass tort, product liability and complex commercial litigation. He frequently tries jury cases to verdict in state and federal courts around the country. Bob also defends mass and class action defendants and has served as part of national defense teams for various consumer products and pharmaceutical defendants. In addition, Bob maintains an active appellate practice. He has appeared as lead appellate counsel six times in the Supreme Court of Virginia and has argued in the Texas Supreme Court, the Texas Court of Appeals, and the U.S. Court of Appeals for the Fifth Circuit. HIS article addresses advanced topics in civil discovery in state and federal courts. It presupposes prior experience in both oral discovery and pretrial procedure. This article focuses on oral civil discovery and is presented in a Frequently Asked Questions (FAQ) format that may be more accessible to seasoned practitioners. Because state court rules are frequently based on the Federal Rules of Civil Procedure (FRCP),' this article generally 1 See e.g. World Mission Soc'y Church of God v. Colon, 85 Va. Cir. 134, 136 (Va. Cir. Ct. 2012) (applying FRCP 26 to interpret the good cause standard under Rule 4:1(c)); Staples Corp. v. Washington Hall Corp., 44 Va. Cir. 372, 374 (Va. Cir. Ct. 1998) (Where the Virginia Supreme Court has not addressed a particular discovery issue, federal case law interpreting the FRCP may be instructive (citing Transilift Equip., Ltd. v. Cunningham,

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