Managing discovery in any case can be time-consuming; however, discovery in a piercing the corporate veil case is especially tedious but essential to proving up or disproving the case.  If a piercing the corporate veil claim survives the initial opposition by the defendant, or motion to dismiss phase, a defendant should expect to receive discovery from the plaintiff, including interrogatories, requests for production and requests for admissions. 

When discovery requests are received by a defendant, defendant’s counsel will meet with the defendant to identify what documents and information are available that is responsive to the plaintiff’s requests and what objections, if any, should be made.  As a defendant, it is imperative to narrow the scope of the discovery, making certain that no business records are produced to the plaintiff that go beyond the plaintiff’s complaint or the requests made, which would very likely damage the defendant’s case.  Defendant’s counsel may also consider moving for a protective order that sets the parameters of the disclosures.   

The next critical stage in the discovery process in a piercing the corporate veil case is the deposition of the defendant’s corporate representative.  How is this person selected?  This person could make or break the case.  Defendant’s counsel usually works with the client to identify the employee with the most knowledge of the issues alleged by the plaintiff.  Although it is laborious, defendant’s counsel must thoroughly prepare the deponent.  A common deposition technique is to ask unsuspecting employees to speculate on the role of other affiliated entities.  It is essential that the deponent does not speculate.  Moreover, it is critical to a defendant’s case that the plaintiff is not given incorrect information that can be spun against the defendant, providing the plaintiff with more ammunition and further damaging the defendant’s case.

If a piercing the corporate veil claim is brought against you or your company, it is essential to invest the time necessary to manage the discovery phase of the case.  The discovery should not be taken lightly or simply dismissed as being “easy.”  Please feel free to contact Iurillo Law Group, P.A to discuss your case and to assist you with navigating the discovery process, which is essential to proving or disproving a piercing the corporate veil claim.

The contents of this blog and website are for informational purposes only and do not constitute legal advice.  Use of and access to this blog and website do not create an attorney-client relationship between the user and Iurillo Law Group, P.A.




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