The Top Discovery Mistakes Paralegals Make

Agenda / Content Covered

All times are shown in Eastern time

1. Discovery Requests Gone Wrong
   11:00 - 11:30, Cari L. Sheehan
   1. Public Records Requests
   2. Interrogatories
   3. Document Production and Inspection Requests
   4. Requests for Admissions
   5. Deposition Requests/Notices
   6. Subpoenas
2. Discovery Response and Document Production Mistakes to Avoid
   11:30 - 12:00, Cari L. Sheehan
   1. Answers and Responses: What NOT to Do
   2. Improper Use of Objections
   3. Answering Subpoenas: Dos and Don'ts
   4. Discovery Deficiencies
   5. Review, Redaction, and Production Oversights
3. Electronic Discovery Pitfalls for Paralegals
   12:00 - 12:30, Cari L. Sheehan
   1. Overlooking Potential Sources of ESI
   2. Preservation Mistakes
   3. Request and Collection Oversights
   4. Review and Production Pitfalls
4. Deposition Prep and Summaries
   12:45 - 1:15, Laurie Chrzanowski
5. Discovery and Document Management Inefficiencies
   1:15 - 1:45, Laurie Chrzanowski
   1. Missed Deadlines
   2. Inefficiencies in Logging and Organizing Discovery Incoming
   3. Inefficiencies in Logging and Organizing Discovery Outgoing
   4. Storage Mistakes
6. Medical Record Mistakes
   1:45- 2:15, Laurie Chrzanowski
   1. Failure to Request and Receive What You Need
   2. Inefficient Organization
   3. Mistakes in Reviewing and Summarizing Medical Records
   4. HIPAA Breaches and Security Concerns

Accreditation Details:

LAURIE CHRZANOWSKI is a paralegal with Tarpine, Heller & Pendergrass, LLC, a boutique workers' compensation defense firm in Columbia, Maryland, serving Maryland and Washington, DC. She works in all capacities of the claim, from beginning investigations through the litigation process. She is experienced with litigation, motions, jury trials, hearings, and the day-to-day handling of medical records and investigations. A certified paralegal, Ms. Chrzanowski is a graduate of Frederick Community College and Stevenson University. She is a member of the National Federation of Paralegal Associations (NFPA) and has taught a number of seminars and webinars for the Institute of Paralegal Education (IPE).

CARI L. SHEEHAN is of counsel in Barnes & Thornburg, LLP's Indianapolis office and is a member of the litigation department. Ms. Sheehan serves as professional responsibility counsel to the firm and focuses on various legal ethics and professional responsibility matters. She has represented clients in state and federal courts in Indiana and Illinois. Ms. Sheehan is admitted to practice in Indiana and Illinois. Ms. Sheehan also is admitted to practice before the U.S. District Court for the Northern and Southern districts of Indiana, U.S. District Court for the Northern and Southern districts of Illinois, U.S. District Court for the Eastern District of Michigan, U.S. Bankruptcy Court for the Southern District of Indiana and Northern District of Illinois, and the U.S. Court of Appeals for the Seventh Circuit. She is a member of the Indiana State Bar Association, Indianapolis Bar Association, and the Saint Thomas More Legal Society. She earned her B.A. degree, cum laude, from the University of Southern Indiana; and her J.D. degree, magna cum laude, from the Indiana University Robert H. McKinney School of Law.