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Strategically Limiting Discovery in Class Litigation: Tactics for Defense Counsel

Leveraging Motions to Stay, Bifurcation Motions, and Cost-Shifting Motions to Reduce Discovery Time and Expense

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, February 3, 2022

Recorded event now available

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This CLE course will guide class action defense counsel for strategically controlling/limiting the time and expense of discovery in class litigation through the use of offensive and defensive motions. The panel will discuss how counsel can leverage motions to stay, bifurcate certification discovery and merits discovery, and cost-shifting motions to reign in discovery costs.


For class action counsel, getting through the discovery process efficiently and cost-effectively is an ongoing challenge. Even seasoned litigators struggle to keep the discovery scope reasonable for each stage of class litigation.

Offensive and defensive motions--including motions to stay discovery pending resolution of a motion to dismiss, to bifurcate class certification versus merits discovery, and to shift costs to the party requesting discovery--are strategic options for defense counsel to limit the time and expense of discovery. Knowing how to leverage these motions successfully is key to reigning in discovery costs.

Listen as our experienced class action defense counsel panel outlines strategic approaches to manage discovery costs, focusing specifically on motions to stay, bifurcation motions, and cost-shifting motions.



  1. Motions to stay discovery pending dispositive motions
  2. Bifurcation: certification vs. merits
  3. Cost-shifting motions
  4. Other strategies to limit discovery


The panel will review these and other key issues:

  • When and how should defense counsel use motions to stay discovery in class action litigation?
  • Under what circumstances should defense counsel seek bifurcation of discovery in class litigation?
  • What are some best practices for using cost-shifting motions as a strategy to limit discovery?
  • What additional methodologies have been effective for defense counsel for conducting discovery in the least expensive manner?


Cassady, Elizabeth
Elizabeth A. Cassady

Steptoe & Johnson

Ms. Cassady is a trial-ready commercial litigator. She is experienced representing global companies and financial...  |  Read More

Pryor, Alan
Alan F. Pryor

Alston & Bird

Mr. Pryor is a senior associate with Alston & Bird’s Litigation & Trial Practice Group. He concentrates...  |  Read More

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