Time: Tue Nov 12 17:13:25 1996
To: Tom Clark <clarktj@valley-internet.net>
From: Paul Andrew Mitchell [address in tool bar]
Subject: broaden our knowledge
Cc: 
Bcc: 

"Practice" makes perfect.

The best way to broaden
your knowledge is to do
exactly what you are doing!!

/s/ Paul Mitchell


At 12:58 PM 11/12/96 -0800, you wrote:
>Paul,
>
>It does feel good to talk about something one has a bit of knowledge and
>experience in.  I just wish the scope of my "law"  experience was broader.
>That will come in time, I suppose.  Right now, I need to document what I
>have learned and experienced to a precise degree.
>
>~Tom Clark
>
>At 08:34 AM 11/12/96 -0700, you wrote:
>>By the way, Tom Clark,
>>this is excellent!!
>>
>>/s/ Paul Mitchell
>>
>>
>>At 01:31 AM 11/12/96 -0800, you wrote:
>>>=======================================================================
>>>LIBERTY LAW - CROSS THE BAR & MAKE YOUR PLEA - FIRST VIRTUAL COURT, USA
>>>Presiding JOP: Tom Clark, Constable: Robert Happy, Clerk: Kerry Rushing
>>>=======================================================================
>>>Hi Randy,
>>>
>>>At 04:58 PM 11/11/96 -0800, you wrote:
>>>
>>><edited for brevity>
>>>
>>>>Randy L. Geiszler here.  Incompatible procedures is one of the greatest
>>>>downfalls of defenses.  This is why mixing procedures together from
>>>>different sources can be a dangereous proposition.  To illustrate what I
>>>>mean, I decided that I should make comments in direct relation to a real
>>>>case and situtation presented in the following post.  
>>>
>>>I think I understand what you are saying about the Demand for Bill of
>>>Particulars.  You assert that seeking discovery is an admission that you
>>>understand the issues and you are ready to defend?
>>>
>>>Theoretically, that makes sense, but do you have any citeable research that
>>>backs that up?  The reason I ask is because I have had excellent results
>>>just by seeking discovery both with and without the questions contained in
>>>Behold!'s Demand for Bill of Particulars.  So, while reason tells me that
>>>you are correct, experience tells me that the issue is not waived by seeking
>>>discovery.  The reason I believe it may not be waived is that Requests for
>>>Discovery, Interrogatories, etc. ARE NOT MOTIONS TO THE COURT.  Indeed,
>>>depending on the state, the paperwork only gets filed if you want the court
>>>to issue an order or your seeking sanctions, etc.
>
><snip>
>
>
      

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