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Discovery Planning

8 published works

  1. Minding Your Business

    Privilege Planning in the New Era

    By Elizabeth Shrieves

    At the end of 2025, amendments were made to the Federal Rules of Civil Procedure that fundamentally change when and how litigators must address privilege issues in federal court. These…

  2. Percipient

    15 Issues to Consider for E-Discovery and ESI Protocols (2021 Update)

    By Chad Main

    Under Federal Rule of Civil Procedure 26(f) and some state court rules like Colorado’s CAPP Rule 6.1, litigants are required to meet and confer early in a case to craft a…

  3. Dig Deeper

    Rule 26(f) Meet and Confer: A Discovery Requirement

    By Steven Toews

    The “meet and confer” requirement imposed by the Federal Rules of Civil Procedure (or, more specifically, FRCP 26(f)) requires that the parties to litigation must, “as soon as practicable” meet…

  4. Resolving Discovery Disputes

    Discovery and the Motion for Summary Judgment

    By Katherine Gallo

    In most practices areas, facts are king. The attorney who can discover and present the best “facts” will be the most persuasive when presenting their case to the judge or jury. However, some…

  5. Resolving Discovery Disputes

    Discovery Plan Part 4 — The Year Before Trial

    By Katherine Gallo

    Somewhere in the back of your mind you are aware that discovery and Motions for Summary Judgment deadlines are looming. Yet, you really don't pay attention to them until they…

  6. Discovery Advocate

    Advocating Cooperation and Proportionality? Study the case law!

    By Gilbert S. Keteltas

    Co-authored by: Alberto Rodriguez In a prior post we noted that those seeking to achieve proportionality in the face of objection by an opponent, or a court’s lack of experience,…

  7. Resolving Discovery Disputes

    Litigate like an Egyptian

    By Katherine Gallo

    You are now sitting down to organize your Discovery Plan and determining what discovery you need to evaluate your case, prepare for mediation, file a motion for motion for summary…

  8. Resolving Discovery Disputes

    Do You Have a Discovery Plan?

    By Katherine Gallo

    As a discovery referee, I normally come into cases when there already is a problem. Either discovery in the case is out of control, or the antagonism among counsel is…