Agenda

1. Making and Responding to Discovery Requests

   1. Notification Process to Parties With Potentially Discoverable Documents
   2. How to Draft Interrogatories and Requests to Produce
   3. Red Flags in Opposing Party's Interrogatories and Requests to Produce
   4. Responses/Objections
   5. Requests for Admission
   6. Notice of Deposition
   7. Practical Insights for Subpoenas

2. Managing Incoming Responses and Documents

   1. Reviewing Discovery Received: What to Look for
   2. Logging and Organizing Incoming Documents
   3. Dealing With Incomplete or Late Responses
   4. Discovery Motions
   5. Storage Tips

3. Document Review, Redaction, Logs, and Production

4. Building an Efficient Discovery Management System

   1. Requesting, Organizing, and Tracking Documents from Clients
   2. Collecting and Managing Documents from Opposing Parties
   3. Collecting and Managing Documents from Third Parties
   4. Managing Electronic Documents
   5. Conducting Ongoing Analysis to Keep Your System Effective

5. Managing E-Discovery

   1. Requesting Electronic Evidence
   2. Identifying, Preserving, and Collecting Electronic Evidence
   3. Processing and Review
   4. Production

6. Discovery Problem Solving - Circumventing Snags in the Process

   1. Retention and Spoliation Issues
   2. Inadvertent Disclosure of Privileged Material
   3. "Corruption" and Other Problems Presented by E-Documents
   4. Non-Production and Other Discovery Violations
   5. Difficult Clients

7. Ethical Issues in Discovery

   1. Conflicts
   2. Tech Competence
   3. Ethics of E-Discovery
   4. Email Ethics
   5. Preserving Confidentiality