timewarpUsually clients do not  understand or want to respond to discovery.  Same with lawyers, but be careful with pre-signed verification forms.  At trial it does not look good when the client testifies he never saw the discovery before.  In Drociak v State Bar (1991) 52 Cal. 3d 1085, a lawyer had obtained several pre-signed verifications from his client. After attempting to locate her without success, and with discovery due, he attached a pre-signed verification as an accommodation to his client to interrogatories he created from information in the client’s file. Drociak was disciplined and suspended for 30 days when it was subsequently learned that his client had died. ‘The use of pre-signed verification in discovery proceedings without first consulting with the client to assure that any assertions of fact are true is a clear and serious violation of the statutes and rules.'”


Photo credit of  the cool clock graphic: Kevin Trotman