Paralegal Pitfalls and Pointers: Pleadings, Motions, Briefs, Discovery Requests and Answers

Agenda / Content Covered

1. Powering Up Your Pleadings, Motions, Briefs, and Citations
   1:00 — 1:45, Jack Luellen
   1. Drafting a Well-Pleaded Complaint
   2. Tips for Drafting Pleadings Around Complex Facts
   3. Witness Statements and Affidavits
   4. Response - Fine-Tuning Defenses, Counterclaims, etc.
   5. Tips for Drafting Various Motions
   6. Creative Insights on Writing Legal Briefs
   7. Practical Tips: Citations and Cite Checking
2. Top 30 Typographical Errors, Grammatical Pitfalls, Words, and Concepts to Avoid
   1:45 — 2:15, Leah Martin
3. Discovery Drafting: Refining Your Requests and Polishing Your Responses
   2:30 — 3:15, Jack Luellen
   1. Interrogatories
   2. Requests to Produce
   3. Requests for Admissions
   4. Subpoenas
   5. Public Records Requests
   6. Drafting Better ESI Discovery Requests
   7. Organizing and Reviewing Documents for Production
4. MS Word, Adobe, and Metadata: Legal Document Creation Insights
   3:15 — 4:15, Laura Danielson
   1. Document Production Tips
   2. Creating Templates
   3. Advanced Formatting Tips
   4. Customizing Your Interface: Modifying Toolbars to Eliminate Extra Clicks
   5. Useful Keyboard Shortcuts
   6. Conversions to and from Other Formats
   7. Document Review and Collaborative Tools
   8. Automating Repetitive Tasks
   9. Restricting Access/Permissions - Customized
   10. Going Paperless with Adobe Acrobat and a Scanner
   11. Creating Editable Forms and Questionnaires with Adobe - Case Study
   12. Creating a Client Intake Questionnaire
   13. Fast, Efficient Legal Document Review in Adobe
   14. Helpful User Tips for Adobe Acrobat (Restricting Access/Permissions, Customizing Menus, Converting Documents from and into PDF Format)
   15. Be Mindful of Metadata (How to Find it, Scrub it, Keep it Intact)

Accreditation Details:

Laura A Danielson is currently the Director of Client Services at HaystackID, Inc. She brings over three decades of experience and is considered an industry expert in the following areas: complex litigation, specializing in consulting, best practices in litigation technology and support; ESI; data management; and trial advocacy for corporations and law firms. Ms. Danielson is a former litigation paralegal and project manager, published author, and frequent speaker/instructor. She has participated in over 100 trials in federal and state courts nationally, and has been on numerous winning trial teams, with her work focused in the areas of intellectual property, product liability, toxic tort, and complex litigation. In addition, she has worked on mock trials, focus groups, arbitrations, and assisted counsel in preparation for mediations. Ms. Danielson holds a bachelor's degree in Political Science, and an associate degree in Paralegal Studies. She holds the following certifications: Certified Records Manager (CRM), Project Management Professional (PMP) Six Sigma-Green Belt, and Six Sigma-White Belt. Currently she is a member of the Project Management Institute (PMI), Association of Records Managers and Administrators (ARMA), Six Sigma, and Women in E-Discovery (WiE) where she is member of the national leadership team for WiE.

Jack R Luellen is a principal of Dickie, McCamey & Chilcote, PC, and the location chair of the Denver office, where his practice is primarily dedicated to oil and gas law, with a particular emphasis on litigation. Mr. Luellen earned his B.S. degree, with distinction, from Colorado State University; and his J.D. degree, cum laude, from the University of Minnesota Law School. Mr. Luellen is admitted to practice in California, Colorado, Utah, and North Dakota. He is a member of the Rocky Mountain Mineral Law Foundation and Energy Mineral Law Foundation.

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.