What should I be including in a defendant's initial disclosures in credit card lawsuit?
The court has set dates for disclosures and discovery. The plaintiff's counsel has submitted their initial disclosures of "individuals with discoverable information and "May" call fact witnesses", as well as "Discoverable documents, data compilations, etc.." with no backup of any documentation yet, but have left themselves open to add supplemental information as it becomes available. What kinds of things should I be requesting on the defendant's side of the disclosures?
