Interrogatories
• Drafting written questions to obtain critical case information from opposing parties.
• Reviewing responses and preparing objections when necessary.

Requests for Production of Documents (RFPs)
• Preparing strategic document requests to obtain key evidence.
• Drafting objections and responses to incoming RFPs.
Requests for Admissions (RFAs)
• Drafting RFAs to establish facts and streamline litigation.
• Preparing responses to RFAs in alignment with legal strategy.

Subpoenas for Records
• Drafting subpoenas to obtain third-party documents, including financial, medical, employment, and communication records.
• Ensuring compliance with federal and state procedural rules.

Deposition Notices & Summaries
• Preparing deposition notices for parties and witnesses.
• Summarizing depositions to highlight key testimony for trial preparation.

Privilege Logs
• Creating detailed logs identifying privileged communications and documents.
• Ensuring compliance with privilege review protocols.
Motions to Compel Discovery
• Drafting motions to enforce compliance with discovery requests.
• Responding to opposing motions to compel.

Protective Orders
• Preparing protective orders to safeguard confidential or privileged information.
• Ensuring compliance with court confidentiality requirements.

Discovery Objections & Responses
• Drafting well-supported objections to improper discovery requests.
• Preparing strategic responses to discovery demands.

ESI Protocol Agreements
• Drafting agreements to govern the format and scope of electronically stored information exchange.
• Ensuring structured and defensible e-discovery processes.

Litigation Hold Notices
• Preparing notices to preserve relevant data and prevent spoliation.
• Monitoring compliance with litigation hold requirements.

Expert Witness Discovery Requests
• Drafting requests for expert reports, prior testimony, and supporting materials.
• Analyzing expert disclosures to prepare rebuttals.