ICBC Claims and Proper Objections to Examination For Discovery Questions

Written by admin on . Posted in BCSC Civil Rule 7, Civil Procedure, Uncategorized.

In one of the more in-depth judicial discussions of examinations for discovery in the context of a personal injury claims, reasons for judgement were released this week by the BC Supreme Court, Vancouver Registry, addressing the scope of proper objections at a Plaintiff’s examination.
In today’s case (Nwachukwu v. Ferreira) the Plaintiff was injured in a 2006 collision.  In the course of the lawsuit the Plaintiff attended three examinations for discovery.  The Plaintiff’s lawyer raised numerous objections during these and the discoveries were ultimately cut short.  The Defendant brought an application directing the Plaintiff to answer the questions which were objected to and further for permission to conduct a lengthier examination for discovery pursuant to Rule 7-2(2).
Mr. Justice Willcock granted the application finding there was “significant obstruction” at the previous discoveries.  In doing so the Court provided the following helpful comments about the scope of discovery and of common objections:

[32] The scope of examination for discovery has recently been canvassed by this court in Kendall v. Sun Life Assurance Company of Canada, 2010 BCSC 1556; More Marine Ltd. v. Shearwater Marine Ltd., 2011 BCSC 166; and Day v. Hume, 2009 BCSC 587.  In those cases, the court reiterated the following principles:  the language of Rule 7-2(18) is identical to the former Rule 27(22) and the scope of examination for discovery has remained unchanged and is very broad.  Rigid limitations rigidly applied can destroy the right to a proper examination for discovery.  Useful or effective cross-examination would be impossible if counsel could only ask such questions as plainly revealed their purpose.  An examination for discovery is in the nature of cross-examination.  Counsel for the party being examined should not interfere except where it is clearly necessary to resolve ambiguity in a question or to prevent injustice.

[33] The time limit established by Rule 7-2(2) creates a greater obligation on counsel for the party being examined to avoid unduly objecting or interfering in a way that wastes the time available.  A largely hands-off approach to examinations for discovery, except in the clearest of circumstances, is in accord with the object of the Rules of Court, particularly the newly stated object of proportionality.  Allowing wide-ranging cross-examination on examination for discovery is far more cost effective than a practice that encourages objections which will undoubtedly result in subsequent chambers applications to require judges or masters to rule on the objections.  It is far more efficient for counsel for the examinee to raise objections to the admissibility of evidence at trial rather than on examination for discovery.  Where intervention is appropriate, the proper conduct of counsel is to state the objection to the form of a question and the reasons for the objection, but it is not appropriate to make comments, suggestions or criticism.

Applicable Law

[34] Many of the specific objections in issue are addressed in an article by John Shields and Howard Shapray published in The Advocate, Vol. 68, pt. 5 (September 2010) at page 671, referred to by Mr. Markham-Zantvoort in argument.

(a) Relevance

[35] Counsel objects to many questions on the grounds that they are not relevant.  In addressing these objections, I proceed from the proposition that counsel should have broad discretion to frame appropriate questions for the examination of the plaintiff, respecting the principles described in the cases to which I have referred.

(b) Confusion

[36] Counsel objects to many questions on the grounds that he finds them confusing.  In Cominco Ltd. v. Westinghouse Canada Limited (1979), 11 B.C.L.R. 142 (C.A.), the Court of Appeal at para. 19 held:

If a question is difficult to answer, the witness can say so and can be cross-examined about the difficulty. It is for the witness, not counsel, to deal with that.  Difficulty in answering does not exclude a whole area. It excludes specific questions.  No area of fact is closed on the ground that to enter it would “open the floodgates”.

(c) Repetition

[37] Counsel objects to questions he considers repetitive.  As Shields and Shapray note, “asked and answered” is not an appropriate objection in Canada.  Madam Justice Boyd in Rec Holdings Co. v. Peat Marwick Thorne Holdings, [1995] B.C.J. No. 1964 (S.C.), held at para. 9:

It is trite law that an examination for discovery is in the nature of a cross-examination.  While there will be situations in which repeating the same allowable question over and over on cross-examination may amount to intimidation, the Court must be slow to interfere where that tactic is used relatively sparingly and particularly in circumstances in which there are good grounds for the cross-examiner’s belief the witness may be falsifying his evidence.

(d) Inadequate Foundation

[38] Shields and Shapray say there is no requirement that a foundation be laid for a question.  In Cominco, the court noted at para. 632:

The objection is that no foundation was laid for the questions.  That suggestion does not appear to have been made at the time and I think that, if one objects, one should say why.  Presuming that this objection can now be made, I merely say that I know of no requirement that a foundation be laid.  None was cited to us.  Those questions should have been answered by the witness without interruption by counsel.

(e) Compound Questions

[39] Counsel routinely objected to questions that he considered to be compounded questions.  Shields and Shapray say, properly in my view, that objection to the form of question should be used sparingly.

(f) Privelege

[40] Counsel objected, at the most recent examination, when the plaintiff was asked what he alleges or says in relation to the claim.  The plaintiff cannot be asked what counsel told him about his claim or how the case will be framed at trial.  He may not be asked how much he will say he has lost, if the answer requires disclosure of an opinion obtained by the solicitor.  Question 1152 on the examination for discovery seems to seek such information.

[41] The witness cannot be asked to disclose how the facts having assembled, weighed or analysed by counsel.  That is what was offensive in the general requests considered by the court inTriathlon Ltd. v. Kirkpatrick, 2006 BCSC 890.  The questions asked in that case were held to offend the description of the privilege afforded to the solicitor’s brief in Hodgkinson v. Simms(1988), 33 B.C.L.R. (2d) 129 (C.A.).  It was the manner of getting at the work product by asking what facts had been assembled by counsel or what facts would be relied upon, rather than by asking about specific facts, that was objectionable.  The manner in which facts have been marshalled is a question going to trial strategy.  It is for that reason that I expect that counsel have included in the book of authorities Blue Line Hockey Acquisition Co., Inc. v. Orca Bay Hockey Limited Partnership, 2007 BCSC 143, although no express reference was made to it in oral submissions.  In that case, questions were held to be objectionable because of what was being sought: conclusions reached by counsel, rather than the evidence of the witness.

[42] Questions that intrude upon privilege are generally objectionable.  That is expressly reflected in Rule 7-2(18).  Care should be taken to protect the solicitor/client relationship.

bc injury law, examination for discovery, Mr. Justice Willcock, Nwachukwu v. Ferreira, objections, Rule 7, Rule 7-2, Rule 7-2(2), Rule 7-2(25), Rule 7-2(3)

Comments (130)

  • browse around this site

    I simply want to mention I am just beginner to blogging and certainly liked this blog site. Almost certainly I’m likely to bookmark your blog . You absolutely have great articles. Thanks for revealing your website.

  • more info here

    I simply want to mention I’m new to blogging and really enjoyed your website. Probably I’m planning to bookmark your website . You amazingly have good posts. Bless you for sharing with us your web page.

  • 릴게임오션파라다이스

    Simply want to say your article is as astounding. The clarity in your post is simply spectacular and i can assume you are an expert on this subject. Fine with your permission allow me to grab your feed to keep updated with forthcoming post. Thanks a million and please continue the rewarding work.

  • fotograf slubny Andrychow

    What’s Going down i am new to this, I stumbled upon this I’ve found It positively useful and it has helped me out loads. I hope to give a contribution & assist different users like its helped me. Good job.

  • Podcast

    We’re a group of volunteers and opening a new scheme in our community. Your website offered us with valuable information to work on. You’ve done a formidable job and our entire community will be thankful to you.

  • venta por catalogo

    I have recently started a site, the info you provide on this website has helped me greatly. Thanks for all of your time & work. “The man who fights for his fellow-man is a better man than the one who fights for himself.” by Clarence Darrow.

  • http://en-invest.com/user/lwswvdkkdjo/

    Please let me know if you’re looking for a article writer for your weblog. You have some really great posts and I think I would be a good asset. If you ever want to take some of the load off, I’d really like to write some articles for your blog in exchange for a link back to mine. Please blast me an e-mail if interested. Regards!

  • marcel van hooijdonk

    I will right away snatch your rss feed as I can not find your email subscription link or newsletter service. Do you’ve any? Kindly allow me recognize so that I could subscribe. Thanks.

  • marcel van hooijdonk

    Hiya, I am really glad I’ve found this info. Nowadays bloggers publish just about gossips and net and this is really annoying. A good site with interesting content, this is what I need. Thank you for keeping this web-site, I will be visiting it. Do you do newsletters? Cant find it.

  • Insektenbekämpfung

    We are a group of volunteers and starting a new scheme in our community. Your website offered us with valuable info to work on. You’ve done an impressive job and our entire community will be grateful to you.

  • beast TV trial

    I loved as much as you’ll receive carried out right here. The sketch is tasteful, your authored material stylish. nonetheless, you command get bought an nervousness over that you wish be delivering the following. unwell unquestionably come more formerly again since exactly the same nearly very often inside case you shield this increase.

  • 야마토게임다운로드

    A person necessarily assist to make seriously articles I’d state. That is the first time I frequented your website page and so far? I amazed with the research you made to create this actual publish extraordinary. Magnificent process!

  • 2D Animation Wien

    I used to be very pleased to find this net-site.I wanted to thanks for your time for this excellent learn!! I definitely having fun with each little bit of it and I have you bookmarked to take a look at new stuff you weblog post.

  • poker online

    My brother recommended I might like this web site. He was totally right. This post truly made my day. You can not imagine simply how much time I had spent for this information! Thanks!

  • situs poker online

    Excellent website you have here but I was curious if you knew of any forums that cover the same topics talked about in this article? I’d really love to be a part of group where I can get feedback from other knowledgeable people that share the same interest. If you have any suggestions, please let me know. Bless you!

  • online poker

    I am really enjoying the theme/design of your website. Do you ever run into any internet browser compatibility problems? A small number of my blog readers have complained about my website not operating correctly in Explorer but looks great in Chrome. Do you have any ideas to help fix this issue?

  • situs poker online

    Do you have a spam issue on this website; I also am a blogger, and I was curious about your situation; many of us have created some nice procedures and we are looking to trade solutions with others, why not shoot me an e-mail if interested.

  • online poker

    I think this is among the most vital information for me. And i’m glad reading your article. But want to remark on few general things, The web site style is wonderful, the articles is really nice : D. Good job, cheers

  • situs poker online

    A lot of thanks for every one of your hard work on this site. Ellie really loves making time for investigation and it is easy to see why. Most people know all relating to the dynamic medium you create very useful information via your web site and in addition inspire participation from other individuals on that theme plus our child has been studying a lot. Take advantage of the remaining portion of the year. You are carrying out a great job.

  • 릴게임다운로드

    Hello, Neat post. There is an issue together with your website in web explorer, might check this… IE still is the marketplace chief and a good part of other folks will pass over your great writing because of this problem.

  • poker

    Great – I should certainly pronounce, impressed with your website. I had no trouble navigating through all tabs and related info ended up being truly easy to do to access. I recently found what I hoped for before you know it at all. Reasonably unusual. Is likely to appreciate it for those who add forums or anything, web site theme . a tones way for your customer to communicate. Excellent task..

  • online poker

    I liked up to you will obtain carried out proper here. The cartoon is tasteful, your authored material stylish. nonetheless, you command get got an nervousness over that you would like be turning in the following. ill unquestionably come more in the past again since exactly the similar just about very steadily inside case you protect this increase.

  • poker online

    I keep listening to the rumor talk about receiving free online grant applications so I have been looking around for the most excellent site to get one. Could you tell me please, where could i get some?

  • מצלמות אבטחה לבית

    A lot of thanks for every one of your efforts on this web site. Ellie delights in making time for investigations and it’s really obvious why. Most people notice all of the compelling tactic you provide effective guidelines on this web site and therefore foster response from other individuals on this topic while our daughter is always studying a whole lot. Enjoy the remaining portion of the new year. You’re doing a terrific job.

  • W88 mobile

    hello!,I really like your writing very much! percentage we keep in touch extra approximately your article on AOL? I need an expert on this house to unravel my problem. Maybe that’s you! Taking a look forward to peer you.

  • Bearking rudra

    I simply couldn’t leave your site before suggesting that I actually loved the usual info a person provide for your visitors? Is going to be back often to investigate cross-check new posts

  • bestpornsites.guide

    Up branch to easily missed by do. Admiration considered acceptance too led one melancholy expression. Are will took form the nor true. Winding enjoyed minuter her letters evident use eat colonel. He attacks observe mr cottage inquiry am examine gravity. Are dear but near left was. Year kept on over so as this of. She steepest doubtful betrayed formerly him. Active one called uneasy our seeing see cousin tastes its. Ye am it formed indeed agreed relied piqued.

  • Воблер голая

    Hi! I know this is kinda off topic however , I’d figured I’d ask. Would you be interested in trading links or maybe guest writing a blog post or vice-versa? My website discusses a lot of the same topics as yours and I feel we could greatly benefit from each other. If you happen to be interested feel free to send me an email. I look forward to hearing from you! Great blog by the way!

  • затворы sung do

    What i do not understood is in fact how you are now not actually a lot more smartly-appreciated than you might be now. You are very intelligent. You recognize therefore considerably relating to this matter, produced me individually consider it from a lot of various angles. Its like men and women aren’t fascinated except it¡¦s one thing to accomplish with Woman gaga! Your individual stuffs outstanding. At all times handle it up!

  • затворы sung do

    I don’t even understand how I finished up right here, however I believed this publish used to be good. I don’t understand who you are however definitely you’re going to a famous blogger when you aren’t already 😉 Cheers!

  • 토토 사이트

    Thank you a bunch for sharing this with all of us you really understand what you’re speaking about! Bookmarked. Please additionally seek advice from my site =). We may have a hyperlink change contract between us!

  • 토토사이트

    I have witnessed that rates for internet degree specialists tend to be a terrific value. For instance a full Bachelors Degree in Communication with the University of Phoenix Online consists of 60 credits at $515/credit or $30,900. Also American Intercontinental University Online offers a Bachelors of Business Administration with a overall education course requirement of 180 units and a tariff of $30,560. Online degree learning has made having your education far less difficult because you might earn the degree in the comfort of your house and when you finish from office. Thanks for all tips I have really learned through the web-site.

  • 토토사이트 추천

    I’ve been surfing online more than 3 hours these days, but I never found any interesting article like yours. It’s pretty value sufficient for me. In my view, if all web owners and bloggers made excellent content as you did, the internet will likely be much more helpful than ever before. “I thank God for my handicaps, for through them, I have found myself, my work and my God.” by Hellen Keller.

  • אוזניות

    Hi! I’ve been following your blog for some time now and finally got the bravery to go ahead and give you a shout out from Austin Texas! Just wanted to say keep up the excellent job!

  • אוניות אלחוטיות

    You actually make it seem so easy with your presentation but I find this topic to be actually something which I think I would never understand. It seems too complicated and very broad for me. I’m looking forward for your next post, I will try to get the hang of it!

  • lifeguard training near me

    Hmm it appears like your blog ate my first comment (it was super long) so I guess I’ll just sum it up what I submitted and say, I’m thoroughly enjoying your blog. I too am an aspiring blog blogger but I’m still new to the whole thing. Do you have any recommendations for novice blog writers? I’d genuinely appreciate it.

  • เช่าเก้าอี้

    I’m impressed, I must say. Really hardly ever do I encounter a blog that’s both educative and entertaining, and let me inform you, you will have hit the nail on the head. Your concept is outstanding; the problem is one thing that not sufficient individuals are talking intelligently about. I am very completely satisfied that I stumbled across this in my seek for one thing regarding this.

  • lifeguard certificate

    Do you mind if I quote a few of your posts as long as I provide credit and sources back to your website? My blog is in the very same area of interest as yours and my visitors would really benefit from some of the information you present here. Please let me know if this alright with you. Thank you!

  • bullet vibrator review

    Wonderful story, reckoned we could combine a couple of unrelated information, nevertheless truly really worth taking a appear, whoa did one learn about Mid East has got much more problerms as well

  • best male masturbator

    Wonderful story, reckoned we could combine a number of unrelated data, nonetheless definitely worth taking a search, whoa did a single understand about Mid East has got more problerms too

  • แต่งงาน

    You really make it seem so easy together with your presentation but I find this topic to be really one thing that I think I’d by no means understand. It kind of feels too complicated and extremely broad for me. I am having a look forward on your subsequent submit, I will try to get the hang of it!

  • 안전놀이터 모음

    Hi there, i read your blog from time to time and i own a similar one and i was just wondering if you get a lot of spam remarks? If so how do you reduce it, any plugin or anything you can recommend? I get so much lately it’s driving me crazy so any support is very much appreciated.

  • 먹튀폴리스 먹튀

    Hmm is anyone else encountering problems with the images on this blog loading? I’m trying to determine if its a problem on my end or if it’s the blog. Any feedback would be greatly appreciated.

  • 먹튀폴리스 먹튀

    Have you ever considered about adding a little bit more than just your articles? I mean, what you say is valuable and all. Nevertheless just imagine if you added some great visuals or videos to give your posts more, “pop”! Your content is excellent but with images and clips, this website could certainly be one of the greatest in its field. Terrific blog!

  • 먹튀폴리스 먹튀

    Hello There. I found your blog the use of msn. That is a very neatly written article. I’ll make sure to bookmark it and return to learn more of your useful information. Thank you for the post. I’ll definitely comeback.

  • w88

    As I site possessor I believe the content material here is rattling wonderful , appreciate it for your efforts. You should keep it up forever! Best of luck.

  • 야마토 게임

    you are actually a good webmaster. The site loading pace is amazing. It seems that you’re doing any unique trick. In addition, The contents are masterpiece. you’ve done a magnificent job in this topic!

  • watch game of thrones online

    Attractive element of content. I simply stumbled upon your weblog and in accession capital to say that I acquire actually enjoyed account your blog posts. Anyway I will be subscribing in your feeds and even I achievement you access persistently rapidly.

  • 더킹 카지노

    I needed to post you that little bit of word just to give many thanks once again about the awesome opinions you have shown on this website. This is incredibly generous with you to provide without restraint what exactly most of us could have sold for an e-book to end up making some money on their own, specifically now that you could possibly have tried it in case you considered necessary. Those thoughts as well acted to be a easy way to understand that other people have similar keenness much like my very own to know the truth lots more concerning this condition. I know there are many more enjoyable occasions up front for many who find out your blog post.

  • where can i watch game of thrones

    Nice post. I used to be checking continuously this blog and I’m inspired! Extremely useful information specially the last phase 🙂 I take care of such info much. I used to be looking for this particular information for a long time. Thanks and best of luck.

  • 우리 카지노

    Magnificent site. Lots of helpful information here. I am sending it to a few friends ans additionally sharing in delicious. And certainly, thank you in your effort!

  • 토토 사이트

    I do trust all of the ideas you have presented on your post. They are very convincing and can definitely work. Nonetheless, the posts are too short for starters. May just you please extend them a little from subsequent time? Thanks for the post.

  • 메이저토토사이트

    One thing I would really like to discuss is that fat reduction plan fast may be accomplished by the proper diet and exercise. People’s size not only affects the look, but also the complete quality of life. Self-esteem, depressive disorders, health risks, as well as physical capabilities are impacted in fat gain. It is possible to just make everything right and still gain. If this happens, a condition may be the perpetrator. While a lot of food and never enough exercise are usually responsible, common medical ailments and trusted prescriptions can easily greatly help to increase size. Many thanks for your post right here.

  • เช่าเก้าอี้

    I believe that avoiding packaged foods may be the first step to be able to lose weight. They will taste good, but processed foods currently have very little nutritional value, making you try to eat more only to have enough power to get over the day. Should you be constantly taking in these foods, converting to whole grains and other complex carbohydrates will make you to have more electricity while consuming less. Good blog post.

  • 먹튀폴리스 가족방

    My brother suggested I would possibly like this web site. He was once totally right. This submit actually made my day. You cann’t consider just how a lot time I had spent for this information! Thank you!

  • livedraw sd

    It’s beautiful value enough for me. In my view, if all web owners and bloggers made good content as you probably did, the internet will likely be a lot more useful than ever before. It is perfect time to make some plans for the future and it’s time to be happy. I’ve read this post and if I could I want to suggest you few interesting things or suggestions. Perhaps you could write next articles referring to this article. I wish to read even more things about it! I have been browsing online greater than 3 hours nowadays, yet I by no means discovered any interesting article like yours. It’s pretty worth enough for me. Personally, if all web owners and bloggers made good content as you probably did, the web might be a lot more useful than ever before.

  • 메이저놀이터

    A person essentially help to make seriously articles I would state. This is the very first time I frequented your web page and thus far? I surprised with the research you made to create this particular publish amazing. Excellent job!

  • 먹튀검증 커뮤니티

    I love your blog.. very nice colors & theme. Did you design this website yourself or did you hire someone to do it for you? Plz answer back as I’m looking to design my own blog and would like to know where u got this from. thanks a lot

  • lifeguard certification

    Hiya, I’m really glad I’ve found this info. Nowadays bloggers publish only about gossips and internet and this is really frustrating. A good web site with exciting content, this is what I need. Thank you for keeping this site, I’ll be visiting it. Do you do newsletters? Can’t find it.

  • 릴게임

    Simply wish to say your article is as amazing. The clearness in your post is simply great and i could assume you are an expert on this subject. Fine with your permission let me to grab your feed to keep up to date with forthcoming post. Thanks a million and please carry on the rewarding work.

  • 먹튀검증 사이트

    Thanks for some other great article. Where else may just anybody get that type of information in such a perfect way of writing? I have a presentation subsequent week, and I am at the search for such info.

  • male sex toys

    we like to honor several other internet web sites around the net, even though they arent linked to us, by linking to them. Beneath are some webpages really worth checking out

  • 파워볼사이트

    Aw, this was a very nice post. In idea I wish to put in writing like this additionally – taking time and actual effort to make a very good article… but what can I say… I procrastinate alot and not at all appear to get something done.

  • W88

    I like this blog so much, saved to favorites. “To hold a pen is to be at war.” by Francois Marie Arouet Voltaire.

  • male masturbator

    Wonderful story, reckoned we could combine several unrelated data, nevertheless seriously worth taking a look, whoa did one particular find out about Mid East has got extra problerms as well

  • clothing

    I cherished up to you will receive carried out proper here. The cartoon is tasteful, your authored material stylish. nonetheless, you command get got an edginess over that you want be turning in the following. unwell definitely come further in the past once more as precisely the same nearly a lot incessantly inside case you shield this hike.

  • custom tees

    I do consider all of the ideas you’ve presented to your post. They are really convincing and can certainly work. Nonetheless, the posts are very brief for newbies. Could you please lengthen them a little from subsequent time? Thanks for the post.

  • Google

    We prefer to honor many other world-wide-web web sites on the internet, even when they arent linked to us, by linking to them. Underneath are some webpages worth checking out.

  • 먹튀폴리스

    I like what you guys are up too. Such intelligent work and reporting! Carry on the excellent works guys I have incorporated you guys to my blogroll. I think it’ll improve the value of my web site :).

  • nonton movie

    Hello there, You have done a fantastic job. I’ll definitely digg it and personally suggest to my friends. I’m sure they will be benefited from this site.

  • nonton film

    Good write-up, I’m normal visitor of one’s web site, maintain up the excellent operate, and It is going to be a regular visitor for a lengthy time.

  • แต่งงาน

    I like what you guys are up too. Such clever work and reporting! Keep up the excellent works guys I have incorporated you guys to my blogroll. I think it’ll improve the value of my web site :).

  • 메이저토토

    Aw, this was a really nice post. In concept I would like to put in writing like this additionally – taking time and actual effort to make a very good article… however what can I say… I procrastinate alot and by no means appear to get one thing done.

  • pembesar penis alami

    Do you have a spam problem on this site; I also am a blogger, and I was curious about your situation; many of us have developed some nice procedures and we are looking to exchange techniques with other folks, please shoot me an email if interested.

  • 메이저토토

    Appreciate you for sharing these kinds of wonderful content. In addition, an excellent travel along with medical insurance approach can often relieve those fears that come with touring abroad. The medical emergency can in the near future become extremely expensive and that’s sure to quickly put a financial burden on the family’s finances. Setting up in place the suitable travel insurance package prior to leaving is definitely worth the time and effort. Thanks

  • backlink

    I simply had to say thanks yet again. I do not know the things I would have made to happen in the absence of those ways contributed by you relating to such a theme. It previously was a real terrifying circumstance in my circumstances, but noticing your specialized fashion you processed the issue forced me to jump with gladness. I’m happy for your information and then believe you comprehend what a powerful job that you’re getting into educating some other people through the use of a web site. I know that you have never come across any of us.

Comments are closed.

Contact

If you would like further information or require assistance, please get in touch.

ERIK
MAGRAKEN

Personal Injury Lawyer

When not writing the BC Injury Law Blog, Erik is the managing partner at MacIsaac & Company, based in Victoria, B.C. He is also involved with combative sports regulatory issues and authors the Combat Sports Law Blog.

“Work hard, be kind and enjoy the ride!”
Erik’s Philosophy

    Disclaimer