Employment Litigation: Pursuing and Defeating Pre-Trial Motions to Dismiss

Leveraging Iqbal Pleadings Requirements and Summary Judgment Standards

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

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Conducted on Tuesday, November 23, 2010

Recorded event now available

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Course Materials

This CLE course will prepare plaintiff and defendant counsel with best practices when seeking to obtain or prevent dismissal and summary judgment. The panel will analyze recent legal developments, including the impact of Iqbal on dismissal motions in employment litigation.


The battle over early dismissal is one of the most critical in employment litigation. Since the Iqbal ruling, motions to dismiss have become a key tool for employers to dispose of claims, and federal courts have dismissed claims in a wide variety of discrimination matters.

Defense counsel must prepare for summary judgment at the early stages of the litigation, recognizing the impact that pleadings and discovery will have on a motion for summary judgment. Plaintiff's counsel must conduct discovery and prepare the plaintiff for deposition with summary judgment in mind.

Listen as our authoritative panel of employment litigators analyzes recent developments in dismissal motion practice and discusses substantive, strategic and practical considerations involved in obtaining and defending motions to dismiss and motions for summary judgment.



  1. Motions to dismiss: defense strategies
    1. Developments in motions practice post-Iqbal
    2. Effective leverage of Iqbal standards
    3. Strategic considerations
  2. Motions for summary judgment: defense strategies
    1. Key documents for affirmative defenses
    2. Depositions and written discovery
    3. Drafting the brief and statement of undisputed facts
    4. Strategic considerations
  3. Plaintiff's strategies for avoiding early dismissal
    1. Overcoming Iqbal pleadings hurdles
    2. Defeating motions for summary judgment
    3. Strategic considerations


The panel will review these and other key questions:

  • Have the Iqbal heightened pleadings standards proven to be a panacea for employers?
  • What are the strategic considerations employers should consider in filing motions to dismiss?
  • What are the most effective deposition and discovery techniques for positioning your case for summary judgment?


Michele L. Maryott
Michele L. Maryott

Gibson Dunn & Crutcher

Her practice focuses on complex business, employment and class action litigation. She has represented employers against...  |  Read More

Teresa Rider Bult
Teresa Rider Bult

Constangy Brooks & Smith

She has successfully tried both jury and non-jury employment discrimination and wage claims, including class claims, at...  |  Read More

Alan Crone
Alan Crone
Kramer & Crone

He represents individuals in employment law matters. He values working within a team to plan strategies and tactics...  |  Read More

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