Litigator's Duty of Reasonable Inquiry in Rule 26(g)(3): Guiding a Client Through Discovery
Recording of a 90-minute CLE video webinar with Q&A
This CLE course will discuss how counsel can objectively satisfy the Fed. R. Civ. P. 26(g) duty to make reasonable inquiry into the client's discovery responses and thereby certify that the client has met its discovery obligations. The program will review what being "actively involved in discovery" means, as a practical matter; what it means to "follow up and validate;" and counsel's options if it cannot make the Fed. R. Civ. P. 26(g) certification.
Outline
- Counsel's duty to supervise client discovery
- Strategies for staying actively involved in discovery
- Strategies for validating client's searches and productions
- Strategies for when client performance falls short
Benefits
The panel will review these and other key issues:
- Why do lawyers continue to struggle with managing discovery?
- What is "knowledge, information, and belief formed after a reasonable inquiry"?
- What have courts identified as less than reasonable inquiry into a client's discovery undertakings and what are the possible consequences, including sanctions?
- How can counsel overcome client objections to their involvement in discovery?
Faculty

Helen Geib
Of Counsel
Hoover Hull Turner
Ms. Geib is Of Counsel for Hoover Hull Turner LLP. Her deep knowledge of eDiscovery law and practice was gained over... | Read More
Ms. Geib is Of Counsel for Hoover Hull Turner LLP. Her deep knowledge of eDiscovery law and practice was gained over many years of experience as a litigator and eDiscovery consultant. Ms. Geib has published numerous articles on topics in eDiscovery and legal technology for a wide variety of publications. In 2019, she was recognized as eDiscovery Professional of the Year by the Indianapolis Bar Association. Ms. Geib obtained her JD, summa cum laude, from The John Marshall Law School and is a member of the bar of the State of Indiana and the US District Court for the Southern District of Indiana. She serves on the board of the Women in eDiscovery Indianapolis chapter, which she launched in 2017.
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Molly E. Broadhead
Attorney
Hoover Hull Turner
Ms. Broadhead is an associate with Hoover Hull Turner LLP. She practices in the area of commercial litigation.
| Read MoreMs. Broadhead is an associate with Hoover Hull Turner LLP. She practices in the area of commercial litigation.
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Che’lee John
Attorney
Hoover Hull Turner
Ms. John is an associate with Hoover Hull Turner LLP. She practices in the areas of corporate and commercial... | Read More
Ms. John is an associate with Hoover Hull Turner LLP. She practices in the areas of corporate and commercial litigation, professional liability defense, and employment disputes.
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