[WSBARP] Off Topic Question

[Inge Fordham]

I have asked this question of plaintiffs to see whether they have been engaged in similar lawsuits (i.e., if they have a proclivity for filing suit).  The threshold for what is considered relevant is pretty low.  If I received an objection, I would also wonder what the plaintiff had to hide (which could lead to further digging).  If there’s nothing to hide, I just answer the question.

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Inge A. Fordham | Attorney
Fordham Law, PLLC
3218 Sixth Avenue | Tacoma, WA 98406
Office: (253) 348-2657 | Mobile: (206) 778-3131
www.fordhamlegal.com<http://www.fordhamlegal.com>

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From: <wsbarp-bounces at lists.wsbarppt.com> on behalf of Douglas Scott <doug at rainieradvocates.com>
Reply-To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Date: Thursday, February 24, 2022 at 11:17 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Off Topic Question

As a plaintiff I have often asked that question, but limited it to a 3 or 5 year period.  I want to see if the defendant has been engaged in similar activities in the past.
DOUGLAS W. SCOTT
Rainier Legal Advocates|LLC

465 Rainier Blvd. N., Suite C
Issaquah, Washington 98027
425.392.8550 (tel)
425.392.2829 (fax)



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On Thu, Feb 24, 2022 at 11:00 AM Nestor Gorfinkel <esq at gorfinkel-law.com<mailto:esq at gorfinkel-law.com>> wrote:
The question is how does answering that lead to other discoverable evidence? It find the question overly broad.
Many times, that question is legitimate when limited in scope and depending on the nature of the case.

Cordially,

Nestor Gorfinkel, Attorney at Law
Licensed in Florida & Washington State
Florida Civil-Law (International) Notary

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From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Jeff at bellanddavispllc.com<mailto:Jeff at bellanddavispllc.com>
Sent: Thursday, February 24, 2022 12:47 PM
To: 'WSBA Real Property Listserv' <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: [WSBARP] Off Topic Question

Listmates,

Clients are involved in a suit involving the collection of promissory notes.  The other side submitted interrogatories asking what other civil proceedings in which the clients have been a party.  I understand the question about a party’s criminal history, but are prior civil proceedings relevant?  Can they be used to attack a witnesses credibility?

Jeff Davis

W. Jeff Davis
BELL & DAVIS PLLC
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com<mailto:jeff at bellanddavispllc.com>
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