Have you ever met someone who just can't tell the same story twice? If so, you might have met Joe Delfgauw. It seems that what ever story he thinks will solve his problem of the moment comes out his mouth, regardless of how it squares with what he said before. That lack of ethics came to bite him as a federal judge had previously dismissed his counterclaim against Nathen Barton, and today granted Nathen Barton's motion for partial summary judgment on Mr. Barton's telemarketin

TCPA lawsuits often require propounding carefully written discovery requests that can't be dodged with a useless answer or an objection that will stick, and then the second problem is compelling answers to the inevitable initial objections and non-answers. I have an earlier post on compelling discovery answers as well. We can learn a lot from a recent discovery dispute and ruling in telephone consumer protection act case Newman v. Aeciq 2025 WL 1592834 (E.D. Cal June 5, 2025)

Previously I wrote about what is a 30(b)(6) deposition and why do you want one, and I noted in another article about a TCPA plaintiff getting the run around that a foundational 30(b)(6) deposition might be useful. But what is a foundational 30(b)(6) deposition? A foundational 30(b)(6) deposition is typically done at the outset of a lawsuit and it isn't intended to get into the merits of the lawsuit, but to understand organization structure, how and where documents are retaine