In a message dated 4/14/2004 11:49:33 AM Eastern Daylight Time, [log in to unmask] writes:

> However, any lawyer worth his salt can and probably
> should request a copy of the schedule as part of the
> discovery process,


Years ago I was enrolled in a legal assistant course of study. One part of that program dealt with litigation. Our assignments required us to draft interrogatories as well as discovery requests. For the interrogatory I included such questions as "does your company have a records retention schedule?"  as well as "do you have a records management manual?"

The attorney teaching the course asked me why I asked such specific questions. (our assignments dealt with a slip and fall case at store) After i explained why, he told me he had never thought to ask such questions and that he would consider using them in the future.


all information is discoverable what you don't want to do is to provide the information up front.
Peter A. Kurilecz CRM, CA
Richmond, Va
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