Written Discovery Fundamentals for Employment Counsel

Crafting Requests for and Responses to Interrogatories, Production and Other Written Discovery

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

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Conducted on Wednesday, February 15, 2012

Recorded event now available

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Course Materials

This CLE course will provide an introduction for employment counsel to the Federal Rules of Civil Procedure for discovery and drafting written discovery including interrogatories, requests for production of documents, requests for admissions, and other written discovery requests.


Written discovery is an essential tool for prevailing in an employment case. Because these suits cover a broad variety of topics, e.g., wage and hour law, discrimination claims, ERISA violations and more, counsel must understand the unique discovery issues involved.

Counsel must carefully craft requests or responses to document requests, interrogatories, requests for admissions, and other written discovery requests to ensure compliance with the discovery rules. Counsel must give constant attention to eliciting or protecting the evidence needed to prove or defend a case.

Listen as our authoritative panel of employment practitioners reviews the discovery rules and provides best practices for basic drafting of documents and procedures for written discovery in particular types of employment claims.



  1. Overview of Federal Rules of Civil Procedure regarding discovery
  2. Interrogatories
  3. Production Requests
  4. Requests for Admissions
  5. Mandatory Disclosures
  6. Requests for Examinations
  7. Requests to Inspect
  8. Best Practices for Utilizing Discovery to Prove or Defend an Employment Case


The panel will review these and other key questions:

  • What key information and documents are most likely to be the subject of discovery?
  • What unique discovery challenges often arise in employment matters?
  • What are the best practices for managing confidential employee information during discovery?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Christopher M. Leh
Christopher M. Leh

Of Counsel
Littler Mendelson

He provides practical advice to employers to help them to comply with the law; anticipate, evaluate and minimize...  |  Read More

Michele L. Maryott
Michele L. Maryott

Gibson Dunn

She is a member of the firm's Litigation Department and its Labor and Employment and Class Actions Practice Groups. Her...  |  Read More

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