Discovery as a beginning
Max is a firm believer in what he calls “effective discovery.” He uses interrogatories to identify “people, places and things” but his true love is a solid set of request for admissions of fact. “I use the KISS Rule and keep them short, simple and right on point,” says Max. And, as Pete says, “I follow the one subject plan. Make them admit each fact one by one. And if they admit it, then you don’t have to prove it.”

Max and Pete will take you through all of the forms of discovery, including physical onsite inspections of the Defendant’s business premises, and how to deal with the professional 30(b)(6) witnesses. Max says that the “typical 30(b)(6) representative is a ‘professional witness’ who will eat your lunch if you don’t know what you are doing.” Pete says, “they will be paying for your lunch after this Boot Camp.” And Pete does not eat cheap, even for lunch!

Setting the tone
The Rule 26 Conference is a critical event in any case. Max and Pete will take you through the ins and outs of these critical meetings and closely review what should always be included in the pre-trial order. Pete says that most cases are settled either “before the answer is filed or on or shortly after the pre-trial conference, so you have to be prepared and know your case cold.” Max says, “there are no real Perry Mason moments; there is only hard work and preparation behind winning cases. The only stipulation I want is an agreement on how much they will pay.”

A real world experience
After learning the ropes of discovery, court will convene at 8:30 a.m. on Sunday morning at the Cleveland County Courthouse. The Hon. F. Donald Bridges, a Senior Resident Trial Judge and a former consumer bankruptcy attorney, will preside over this special Boot Camp term. After some key courtroom tips and tricks from the Judge (including how to keep the Judge happy), the Boot Campers will meet the Hon. Sandra Arnold, who served the State of North Carolina as an Official Court Reporter for more than 30 years. During this period, Sandy also took over 5,000 private depositions. Sandy will provide the Boot Campers with her own private list of the Top 100 most common mistakes she has observed attorneys make during depositions.

Following Sandy’s remarks, Max and Pete will take the Boot Campers through a real deposition with Max and Pete taking opposite sides. After this presentation, each Boot Camper will be required to conduct a partial direct examination of a witness under oath and will have their questions critiqued by Judge Bridges, Sandy, Pete and Max. This is a pretty tough jury so this part will not be easy.

The courtroom experience
Following the depositions, Judge Bridges will then preside over approximately 25 vignettes, with each one related to a common evidence problem encountered at most trials and evidentiary hearings. Max and Pete will cover everything including judicial admissions, judicial notice, to selfauthenticating evidence, common hearsay exceptions, entering bills, tapes, letters, photographs into evidence and much more. . . Judge Bridges will rule on each and every objection, and will explain the factual and legal basis of each ruling. More importantly, the Judge, along with Max and Pete, will explain how the objectionable evidence may have otherwise been admissible if another approach had been employed.

A place to rest and recharge
This truly unique and special Boot Camp will be limited to 15 attorneys. The Boot Camp fee includes free transportation to and from the Charlotte Douglas International airport and what can only be described as truly outstanding and outright luxurious accommodations at Max’s geographically remote and scenic South Mountain Farm. All food will be prepared by Max’s wife, Victoria, who was the Master Chef at Max and Victoria’s former Four Star and Four Diamond Bed & Breakfast Inn at Historic Webbley in Shelby. Many of Max’s Boot Campers have said as good as the Boot Camp was as a learning experience, Victoria’s Food may have been better!