Discovery question

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PrdHrdlrDad

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I would appreciate any response.
I am a pro se litigant in a federal lawsuit. I have a few pages of hand-written notes to myself that I have accumulated over the last 3 1/2 years regarding my complaint. The defendants' key witness has lied numerous times during an investigation prior to the filing of my complaint and in discovery since. Some of these lies I can prove due to the fact that their version is literally impossible. They do not realize how their witness has lied himself into a corner. There are numerous, seemingly trivial, bits of information that render their version an obvious string of lies. I have contended from the start to their attorney that his client is lying and that I can prove a lot of the lies. Now their attorney is in the process of filing a motion to compel to force me to explain to him how I can prove the lies. Ordinarily I wouldn't mind but his client has already "refined" their lies after a mediation session two years ago. With the help of an attorney representing them at that point, they just formulated more and deeper lies to explain away the lies that they were caught in then. He claims that he is entitled to any and all notes to myself that I have kept regarding how I can prove the lies. He also claims that he will ask me in deposition, "How can you prove that my client is lying?"
What exactly is their attorney entitled to regarding my potential questions I will ask their witness under oath at trial to expose the lies?
 
He's not entitled to your notes unless he can prove some sort of exception to work-product privilege. You don't need to be a lawyer to claim it. If he wants to know what his client said under oath, he can go get transcripts. If he asks you in deposition how you can prove his client is lying, invoke privilege and refuse to answer.
 
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