Managing Class Representative Discovery: Plaintiffs' Strategies for Winning Certification
Preparing for Discovery Pre-Suit, Negotiating Fair Protocols, Defending Depositions, and Responding To Written Discovery
Recording of a 90-minute CLE video webinar with Q&A
This CLE webinar will provide strategies for plaintiffs’ counsel to navigate class representative discovery. The panel will discuss best practices related to preparing for discovery, negotiating fair discovery protocols, responding to discovery requests, and defending class representative depositions.
- Selecting the named plaintiff with an eye to discovery
- Selecting and gathering documents before commencing the case
- Anticipating key defense strategies
- Negotiating protocols and protective orders
- Responding to written discovery requests
- Preparing for and defending depositions
The panel will review these and other crucial questions:
- What are the most difficult issues for plaintiffs to navigate during discovery?
- What protocols are the most important?
- What types of questioning techniques might be anticipated at depositions?
- What can counsel do during and after a deposition if the deponent performs poorly?
Baron & Budd
Mr. Fernandes represents clients across the United States in class action litigation involving automobile safety,... | Read More
Mr. Fernandes represents clients across the United States in class action litigation involving automobile safety, negligent banking practices, and deceptive advertising.Close
Phong-Chau G. Nguyen
Lieff Cabraser Heimann & Bernstein
Mr. Nguyen is a partner in Lieff Cabraser’s San Francisco office specializing... | Read More
Mr. Nguyen is a partner in Lieff Cabraser’s San Francisco office specializing in consumer and defective product cases, as well as personal injury/mass tort matters. He is part of the leadership team in the Volkswagen Diesel Emissions multidistrict litigation, which secured an unprecedented $14+ billion in settlements on behalf of U.S. owners and lessees of Volkswagen diesel vehicles, won the California Daily Journal’s “California Lawyer of the Year” award, and secured a finalist position for the 2017 Consumer Attorneys of California “Consumer Attorneys of the Year” award. Mr. Nguyen is also involved in similar work on Lieff Cabraser’s leadership team in the Fiat Chrysler diesel emissions case.Close