Discovery

Discovery of Experts

A book chapter authored by Tom Williamson, Jr. and published in Civil Discovery in Virginia. To obtain a copy of the complete publication, go to the Virginia CLE website.

Motion to Compel Defendant to Answer Deposition Questions

The attached brief was filed to compel the defendant in a medical malpractice case to answer questions under oath without interference by his attorney.

Brief to Compel Production of Hospital Incident Report

This brief was filed by attorney Tom Williamson to compel a hospital to produce its incident report in a medical malpractice case. In this case, the patient fell and suffered a fatal head injury at the hospital. Tom filed this brief after the hospital refused to produce its incident report describing the facts surrounding the patient’s fall at the hospital.

Memorandum In Support of Compelling Production of Secret Surveillance Videos

The attached memo was used in support of our argument that the defendant can not surprise the plaintiff with secret surveillance videos at trial.