Effective Class Action Discovery Strategies

Best Practices for Depositions, Expert Witnesses and E-Discovery

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

This seminar will discuss common discovery obstacles in class action litigation and will provide strategies for counsel on cost-effective approaches to managing the discovery process.


Pursuing and responding to discovery requests in an efficient, cost-effective manner is an ongoing challenge for class action counsel. Even seasoned litigators often struggle to determine the most effective techniques for taking depositions, using expert witnesses and managing e-discovery challenges.

Discovery is critical at all stages of the class action case. Evidence obtained during the pre-certification phase can help determine whether a class will be certified. Further, parties can use discovery to help resolve jurisdictional questions arising under the Class Action Fairness Act (CAFA).

Listen as our panel of seasoned class action litigators examines common discovery challenges that arise in class action litigation and provides best practices for counsel on managing the discovery process in a way that saves time and money.



  1. Introduction and overview
  2. Removal and CAFA
  3. Motions to stay discovery pending dispositive motions practice and class certification timing requirements
  4. Organizing and coordinating plaintiffs counsel
  5. Bifurcation: class versus merits discovery
    1. Considerations and strategy
    2. Practical effects (or not)
  6. Class discovery and timing issues
    1. Discovery of lead plaintiff/preparing lead plaintiff
    2. Discovery of and from absent class members/plaintiffs perspective
    3. Plaintiff’s discovery-shot gun or sniper?
    4. Use of experts
  7. Rule 23 class certification requirements — how to satisfy or disprove through discovery
  8. E-Discovery
  9. Special considerations
    1. MDL
    2. Settlement considerations


The panel will review these and other key questions:

  • What are the most common discovery challenges class action litigators face — from initiation through resolution of the case?
  • How are defense attorneys using e-discovery to defeat class certification?
  • How are plaintiff's counsel responding to requests for discovery of class members — both named and unnamed?
  • What strategies have been effective for plaintiff and defense counsel for obtaining essential information in the least expensive manner?


Donna L. Wilson
Donna L. Wilson

Kelley Drye & Warren

She has experience in litigation and counseling in the areas of consumer financial services and insurance recovery. She...  |  Read More

Robert J. Bonsignore
Robert J. Bonsignore
Bonsignore & Brewer

He focuses on complex business litigation, consumer protection, class actions and multi-district litigation. He has...  |  Read More

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Strafford will process CLE credit for one person on each recording. All formats include program handouts.

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