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29 Pretrial Prac. & Discovery [i] (2021)

handle is hein.aba/pretpd0029 and id is 1 raw text is: Spring 2021, Vol. 29 No. 1
TABLE OF CONTENTS

Articles n
CC'ed Emails and Attorney-Client Privilege
By Robert D. Keeling
There is a false perception that emails with an attorney copied only on the CC line are not privileged.
Dangerous Client Communications
By Michael Roundy
Confidential communication with our clients is essential to our work. Here are some best practices for
protecting it.
Translations 101
By Joseph V. Schaeffer
Litigation involving foreign-language documents presents unique challenges. Here are some lessons
I've learned.
In Limine Motions: Set the Battlefield for Success
By Jeffrey M. Pollock
Use in limine motions to shape your theme during discovery.
Practice Points))
Depositions: Avoiding the Great Fishing Expedition
By Michael Schwarz
The deposition process should never be used as a vehicle for intimidation. Yet, we all know that it is
sometimes the strategy to rile the witness to forget important facts or misstate them.
The Perils of Shotgun Pleadings: The Case for the Focused over the Scattershot Approach
By Eoin Moynihan
The advice of Winston Churchill is as instructive today as it was 80 years ago.

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