Defending ERISA Conflict of Interest Discovery Requests

Limiting the Scope of Discovery, Preparing and Defending 30(b)(6) Depositions, and More

Recording of a 90-minute premium CLE webinar with Q&A

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Conducted on Thursday, March 27, 2014

Recorded event now available

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Course Materials

This CLE course will prepare ERISA counsel to effectively handle conflict of interest discovery requests. Our experienced panelists will provide best practices in defending discovery requests to include 30(b)(6) depositions.


Prior to Metropolitan Life Ins. Co. v. Glenn, discovery beyond production of the official administrative record compiled during a claims review was generally not permitted in ERISA cases. After Glenn, claimants may now use discovery to explore the scope of a conflict of interest.

With the door opened for additional discovery in ERISA cases, depositions in employee benefit cases are more frequently allowed especially with regard to discovering information on an administrator’s conflict of interest.

In addition to increased discovery requests, the 30(b)(6) deposition request is the most troublesome. Counsel must be prepared to defend these requests in light of varying federal court treatment to include some courts allowing very broad discovery requests. 

Listen as our authoritative panel provides their perspectives, experiences and best practices in limiting discovery requests, preparing for and defending 30(b)(6) depositions, selecting and preparing witnesses, and more.



  1. Defending discovery requests
    1. Protective orders
  2. Strategies for preventing or limiting 30(b)(6) depositions on conflict of interest issues
  3. Selection and preparation of the witnesses
  4. Defending the company witness in the deposition
  5. Using the deposition to dispute conflict of interest allegations


The panel will review these and other key questions:

  • What types of conflict of interest discovery requests can be expected in ERISA litigation?
  • What strategies should be implemented to limit discovery requests?
  • How can you prevent or limit the burdensome 30(b)(6) deposition?
  • What are the best practices for selecting, preparing and defending a company witness in a 30(b)(6) deposition?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Jack F. Fuchs
Jack F. Fuchs

Thompson Hine

Mr. Fuchs, a Partner in the firm's Employee Benefits & Executive Compensation, ERISA Litigation, and Business...  |  Read More

Springer Ayeni, Cassie
Cassie Springer Ayeni

Springer Ayeni

Ms. Springer is an experienced ERISA litigator representing claimants, and is a former Co-Chair on the Benefit Claims...  |  Read More

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