The worst. We answered interrogatories by referring to documents under Rule 33 (d) which was especially appropriate s...
The worst. We answered interrogatories by referring to documents under Rule 33 (d) which was especially appropriate since the client was not familiar with the documents, but she made us re-do them. We spent hours getting everything we could out of the documents to supplement the interrogatories. Meanwhile my adversary took two depositions that violated a court order limiting discovery. She made us answer the interrogatories again and said my adversary's questions were proper. She knew nothing about the case. Our third set of interrogatory answers looked like the Manhattan yellow pages. She still wanted to throw the book at us but I made a spirited argument that caused her to wait four days before issuing minor sanctions. When the parties filed summary judgment motions, my adversary made a motion to strike our papers and cited ten instances where they said we had violated one of her orders. Our opposition stated that they literally lied to her ten times, and we had not violated her order. She granted their motion, which effectively decided the case, but in a subsequent order awarding my adversary sanctions, she stated she never read our papers. If she is reappointed it will be a disaster. r