Discovery Responses and Document Production: A Paralegal's Ultimate Guide

Agenda / Content Covered

1. Responding to Requests: Rules, Pitfalls, and Tips
   11:00 — 11:45, Leah Martin
   1. Interrogatories
   2. Requests for Admissions
   3. Requests for Production of Documents
   4. Subpoenas (for Deposition/Documents)
   5. Deposition Notices
   6. Public Records Requests
2. Proper Use of Discovery Objections
   11:45 — 12:30, Leah Martin
   1. Overview of Discovery Objections (w/Master List)
   2. When and How to Use Common Objections
   3. Buzzwords and Getting Your Phrasing Right
   4. Commonly-Misused Objections
   5. Attorney Preferences and Practical Pointers
3. Document Review and Production
   12:45 — 1:45, Leah Martin
   1. Finding, Collecting, and Organizing Documents
   2. Reviewing the Documents to be Produced
      1. Relevance and Responsiveness
      2. Privileges and Confidentiality
      3. Other Issues to Watch Out For
   3. Bates-Stamping
   4. Redaction
   5. Duplication
   6. Indexing of Documents
   7. Producing the Requested Documents; Submission/Service
   8. Managing Large-Volume Document Productions
   9. Common Mistakes in Document Production
4. Electronic Productions; Preserving, Collecting, and Producing ESI
   2:15 — 3:15, Karin Scheehle
   1. E-Discovery Rules and Case Law You Need to Know
   2. Preserving ESI/Legal Hold Notices
   3. Formulating an E-Discovery Plan
   4. Collecting, Processing and Reviewing ESI
   5. Producing ESI
   6. Common Missteps With Respect to ESI
5. PDF, TIFF, and Native File Productions: Paralegal Tips and Tricks
   3:15 — 4:00, Karin Scheehle
6. Discovery, Privilege, and Production Logs (w/Samples)
   4:15 — 5:00, Karin Scheehle
   1. What to Log, What Not to Log - Best Practices
   2. Discovery Responses
   3. Subpoena Logs
   4. Deposition Logs
   5. Client Document Logs
   6. Privilege and Redaction Logs
   7. Production Logs
   8. Electronic Discovery Logs
7. Ethical Issues in Discovery for Paralegals
   5:00 — 6:00, Karin Scheehle
   1. Confidentiality and Privilege
   2. Inadvertent Disclosures: Sender vs. Receiver
   3. Ethical Issues in E-Discovery
   4. Handling Uncooperative or Untruthful Clients

Accreditation Details:

LEAH A. MARTIN is managing partner at Leah Martin Law. She brings many years of experience in all areas of business law, including preparing formation documents; drafting operating and shareholder agreements, partnership agreements, purchase and finance agreements, leases, surrender agreements, non-compete and non-disclosure agreements, and employment agreements; contract litigation; shareholder derivative suits; business dissolutions; and appellate matters. She has been a grader for the Nevada bar exam since 2008. Ms. Martin has chaired the Clark County Law Foundation Community Service Committee, having served on the committee since 2007. In addition to maintaining her own cases, she also has been an arbitrator on the Court Annexed Arbitration Program Panel since 2012. Ms. Martin is currently licensed with the State Bar of Nevada, and is certified to practice in the U.S. District Court for the District of Nevada and the Ninth Circuit Court of Appeals. She is a member of the American Bar Association, State Bar of Nevada, Clark County Bar Association, and Southern Nevada Association of Women Attorneys. Ms. Martin earned her B.A. degree, summa cum laude, from the University of Nevada Las Vegas; and her J.D. degree, summa cum laude, from the University of Nevada Law Vegas School of Law.

KARIN M. SCHEEHLE is a litigation paralegal for Gallagher & Kennedy in Phoenix, Arizona, working on multi-million dollar personal injury cases. She has more than 30 years of experience working in the legal profession and is an experienced litigation paralegal, law firm administrator, and technology manager. Although the vast majority of her experience has been in litigation, she has also worked in other areas of the law including real estate, corporate, admiralty, and administrative law. Ms. Scheehle has assisted in more than 50 trials in California, Texas and Arizona, including the largest securities trial in Maricopa County where more than 9,000 exhibits were marked and more than 60 witnesses testified. She specializes in technology enhanced case management and electronic trial presentation. Ms. Scheehle received her certified paralegal designation from the National Association of Legal Assistants (NALA) and several advanced certifications in litigation, personal injury, and e-discovery. She has a B.S. degree in management, graduating with honors; and an M.B.A. degree with emphasis in technology management. Ms. Scheehle is a certified case logistics administrator and a certified ediscovery specialist. She has taught numerous seminars both locally and nationally, predominately in the areas of litigation, technology, ethics, case management, and law firm management. Ms. Scheehle has had articles published in both local and national publications. She has also served as a guest lecturer at several legal assistant schools and currently teaches as adjunct faculty in the ABA approved legal studies program at Phoenix College in Phoenix, Arizona. Ms. Scheehle served on the Board of Directors of the Arizona Paralegal Association for 15 years and NALA's Board of Directors for 10 years. She also served on NALA's Certifying Board for three years and on the Professional Development Committee for three years (including two years as chair). Ms. Scheehle served on several NALA committees tasked with developing advanced certification courses and is a frequent lecturer for NALA Campus Live and co-presented technology-related seminar tracks at three NALA national conventions.