Discovery Strategies in Personal Injury Litigation Under Amended Rules 26(b) and 34(b)
Drafting or Responding to Interrogatories, Requests for Production of Documents or Admission of Facts, and Third-Party Subpoenas
Recording of a 90-minute CLE webinar with Q&A
This CLE course will guide personal injury litigators in drafting discovery requests likely to survive heightened judicial scrutiny under recent amendments to Rule 26(b) of the FRCP. The panel will also discuss tactics for objecting to discovery requests that are overly burdensome and producing documents and electronically stored information in a timely manner as required by amended Rule 34(b).
- FRCP amendments and requirements: an overview
- Recent case law
- Drafting discovery requests
- Responding/objecting to discovery requests
The panel will review these and other key issues:
- When drafting discovery requests, what should personal injury counsel consider to ensure that requests meet the proportionality standard?
- When responding to early requests for production, what is the standard for specificity for litigators’ objections?
- What constitutes “reasonable time” for producing information?
- How does case law establish when the burden or expense of obtaining discovery outweighs the likely benefit?
Patricia E. Antezana
Ms. Antezana focuses her practice on general litigation, including commercial matters, business torts and product... | Read More
Ms. Antezana focuses her practice on general litigation, including commercial matters, business torts and product liability defense, with a specialty in managing e-discovery issues. She has been involved with all phases of litigation, including management of large-scale discovery, dispositive motions, trial preparation and alternative dispute resolution. Ms. Antezana has coordinated electronic and hard copy record collection and managed large-scale review projects in numerous complex litigation matters.Close
Andrew D. Gross
Kosieradzki Smith Law Firm
Mr. Gross focuses on medical malpractice cases, nursing home abuse and neglect cases, civil rights actions, and... | Read More
Mr. Gross focuses on medical malpractice cases, nursing home abuse and neglect cases, civil rights actions, and trucking and auto collision cases. Andrew is dedicated to assisting his clients navigate complex legal and medical issues. A frequent speaker on personal injury trial techniques, he is a member of the Minnesota Association of Justice, the American Association of Justice, and the Association of Plaintiff Interstate Trucking Lawyers of America.Close