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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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