Discovery
The time frame to respond to Requests for Production of Documents
What is 30 days?
If you believe that a witness is uncooperative with the opposing party, you may want to call them as this.
What is a hostile witness?
The July 2025 non-precedential opinion of Lapenta v. Fagan stresses that a trial court may award these while also stressing that the parties “focus less on damaging each other financially, but rather on improving their behavior.”
What are Counsel fees; attorney’s fees?
Lawyers are required to be honest and truthful which includes not knowingly making false statements of fact or law even in the name of advocacy.
What is lack of candor with the court/tribunal?204 Pa. Code r. 3.3 - Candor Toward the Tribunal
“Heeelloooo!” Robin Williams disguises himself to spend more time with his children after a divorce in this film.
What is Mrs. Doubtfire?
A Court may enter this type of Order upon Motion by a party or by the person whom discovery or deposition is sought to protect a party or person from unreasonable annoyance, embarrassment, oppression, burden or expense
What is high conflict custody matters?
This hearsay exception requires a document to be 30 years or older.
What is the “ancient documents” exception?
The March 2025 Superior Court decision of Hillberry v. Hillberry determined that the terms and conditions regarding these individuals in a custody case would ensure the safety of the child.
Who/What are Custody supervisors?
Some lawyers provide communications and documents to the court without the other attorney present or included on the communication in an effort to bias the court.
What is an ex parte communication with the court? 237 Pa. Code Rule 1136. Ex Parte Communication.
In this 1994 movie, a divorced dad's relationship with his son is tested when his custody is revoked due to his magical transformation—and his son's belief in it.
What is The Santa Clause?
Requirement that a party seeking production of documents from a person not a party to the action give this to every other party in the action of their intent to serve a subpoena before the date of service.
What is written notice of Intent to Serve a subpoena?
One of the elements of this hearsay exception is that the record was of a business activity.
What is a record of regularly conducted activity?
This blockbuster 2025 Pennsylvania Supreme Court case established parentage by intent in the context of the parties’ use of a assisted reproductive technology.
What is Glover v. Junior?
A lawyer should not make disparaging personal remarks or engage in acrimonious speech or conduct toward opposing counsel in the legal process and should not attempt to bring the attorney into disrepute by making unfounded accusations of impropriety or personal attacks upon counsel.
What are the lawyers' duties to the court and to other lawyers? 204 Pa. Code § 99.3
In this 1997 comedy, Jim Carey plays a lawyer who, outside of the courtroom, has ongoing custody disputes with his ex-wife regarding their son, Max.
What is Liar Liar?
If a deposition is to be taken by oral examination more than 100 miles away, upon Motion, the court may do this.
What is making a recommendation that affects primary custody or legal custody on a permanent basis?
This Rule, formally known as Rule 1002 - Requirement of the Original, applied only to writings but it may apply to recordings or photographs.
What is the Best Evidence Rule?
In the May 2025 opinion for In re C.E.D.H., the Superior Court held that the trial court in a termination of parents rights case erred by not noting the objection made by these individuals for the subject child.
Who is Counsel for the child or GAL?
The Pennsylvania Rules of Professional Conduct, which govern attorney ethics, are located in Title 204, Part II, Chapter 81 of the Pennsylvania Code, specifically 204 Pa. Code § 81.4. These rules can be accessed online via the Pennsylvania Code website.
What should every attorney read, then read again??
In this 1998 film, a couple's custody battle over their children becomes central to the story, starring Diane Keaton and Jack Nicholson
What is Something’s Gotta Give?
A neutral third party who may be appointed by the court to take control of and manage property or assets, including businesses, that are subject to a legal dispute, especially useful in cases where a business, or property is being mismanaged (or appears to be mismanaged)
Who is a receiver?
This Rule requires the availability of originals in order to be admitted.
What is a summary exhibit.?
With the May 2025 case of Layton v. Layton, the Superior Court remanded the matter because the trial court—after rejecting the hearing officer’s findings and recommendation on a nuptial agreement—failed to do this.
What is Make its own findings; make its own reasoning?
One attorney made offer after offer of settlement to opposing counsel in an effort to resolve the issue without litigation but as soon as the offer was made, the attorney rejected it. The offers were rejected so quickly that the client was not aware of the offers before they were rejected.
What does an attorney always have to communicate to the client promptly?
Rule 1.41 of the Pa Rules of Professional Conduct. Mandates prompt communication of all settlement offers to the client who has the ultimate authority to accept or reject a settlement offer.
In "Kramer vs. Kramer," Dustin Hoffman’s character fights for custody of this young boy.
Who is Billy?