Litigation & Appeals

Live Online

Mastering Written Discovery: Interrogatories, Requests for Production, Admissions, and Subpoenas

Credits Available
Credit Status Total
Alaska CLE Reciprocity 6 Total
Alabama CLE Approved 6 Total
Arkansas CLE Approved 6 Total
Arizona CLE Approved 6 Total
California CLE Approved 6 Total
Colorado CLE Approved 7 Total
Connecticut CLE Approved 6 Total
Delaware CLE Approved 6 Total
Florida CLE Approved 7 Total
Georgia CLE Approved 6 Total
Hawaii CLE Approved 6 Total
Iowa CLE Approved 6 Total
Idaho CLE Pending 6 Total
Illinois CLE Approved 6 Total
Indiana CLE Approved 6 Total
Kansas CLE Approved 7 Total
Kentucky CLE Upon Request 6 Total
Louisiana CLE Approved 6 Total
Maine CLE Approved 6 Total
Minnesota CLE Approved 6 Total
Missouri CLE Approved 7.2 Total
Northern Mariana Islands CLE Approved 6 Total
Mississippi CLE Approved 6 Total
Montana CLE Pending 6 Total
North Carolina CLE Approved 6 Total
Nebraska CLE Approved 6 Total
New Hampshire CLE Approved 6 Total
New Jersey CLE Approved 7.2 Total
New Mexico CLE Approved 6 Total
Nevada CLE Approved 6 Total
New York CLE Approved 7 Total
Ohio CLE Approved 6 Total
Oklahoma CLE Approved 7 Total
Pennsylvania CLE Approved 6 Total
Rhode Island CLE Upon Request 7 Total
South Carolina CLE Approved 6 Total
Tennessee CLE Approved 6 Total
Texas CLE Approved 6 Total
Utah CLE Approved 6 Total
Virginia CLE Approved 6 Total
Vermont CLE Approved 6 Total
Washington CLE Approved 6 Total
Wisconsin CLE Approved 7 Total
West Virginia CLE Approved 7.2 Total
Wyoming CLE Approved 6 Total
Live Online
6 hours
Spencer Aronfeld
Christopher Campbell
Richard Leefe
John Tate
David Lowe
With Spencer M. Aronfeld from Aronfeld Trial Lawyers + 4 others

Wed, Nov 04, 00:00 AM – 00:00 PM

Product ID 102629

Register For Course

Course Includes
$429

Live Webinar Registration

OnDemand Recording

Course Book Download

OnDemand content will be available within 7 days of event date.

or
Upgrade to Unlimited CLE and Get This Course
$129/Month
All Inclusive CLE subscribers save an average of $3,000/year on CLE costs.

Overview

Strategic Discovery in the Age of ESI and AI

Discovery is where cases are often won or lost. Boilerplate document requests, overlooked RFAs, and reactive dispute management are costing litigators time, money, and leverage. Are you leaving value on the table?

This CLE transforms how you approach written discovery. With practical, tool-by-tool instruction, drafting guidance, sample language, and strategic insights drawn from decades of experience, you will leave with immediately usable skills, templates, and tactics. Litigate smarter and more efficiently - register today!

  • Transform interrogatories from rote exercises into a precision tool for admissions and facts.
  • Win the document battle with smarter RFPs.
  • Unlock the full power of RFAs, the most underused weapon in civil discovery.
  • Master third-party subpoenas, including ones for medical, financial, and employment records.
  • Use AI to draft better and review faster.
  • Resolve disputes effectively and build the record for sanctions when you need it.

*Any mention of specific products in this program is intended as part of a general overview and does not constitute NBI's endorsement or recommendation of any specific product or provider. This program is not sponsored by any technology or electronics provider.

Abbreviated Agenda

  1. Get What You Need and Give Only What You Must
  2. Interrogatories: From Boilerplate to a Strategic Tool
  3. Requests for Production: Winning the Document Battle
  4. Requests for Admission (RFAs): The Most Underutilized Discovery Weapon
  5. The Subpoena Arsenal (With Sample Language)
  6. Using AI to Transform Discovery Drafting and Review (With Demos)
  7. Discovery Disputes, Motions to Compel, and Sanctions (With Sample Letters and Motions)
  8. Ethics and Professional Responsibility in the Age of ESI and AI

Can't Attend Live?

Get the OnDemand Instead

Watch the recording of this event on your own schedule. We'll notify you when its ready.

Related Topics

Product ID 102629

Credit Details

Credits Available
Credit Status Total
Alaska CLE Reciprocity 6 Total
Alabama CLE Approved 6 Total
Arkansas CLE Approved 6 Total
Arizona CLE Approved 6 Total
California CLE Approved 6 Total
Colorado CLE Approved 7 Total
Connecticut CLE Approved 6 Total
Delaware CLE Approved 6 Total
Florida CLE Approved 7 Total
Georgia CLE Approved 6 Total
Hawaii CLE Approved 6 Total
Iowa CLE Approved 6 Total
Idaho CLE Pending 6 Total
Illinois CLE Approved 6 Total
Indiana CLE Approved 6 Total
Kansas CLE Approved 7 Total
Kentucky CLE Upon Request 6 Total
Louisiana CLE Approved 6 Total
Maine CLE Approved 6 Total
Minnesota CLE Approved 6 Total
Missouri CLE Approved 7.2 Total
Northern Mariana Islands CLE Approved 6 Total
Mississippi CLE Approved 6 Total
Montana CLE Pending 6 Total
North Carolina CLE Approved 6 Total
Nebraska CLE Approved 6 Total
New Hampshire CLE Approved 6 Total
New Jersey CLE Approved 7.2 Total
New Mexico CLE Approved 6 Total
Nevada CLE Approved 6 Total
New York CLE Approved 7 Total
Ohio CLE Approved 6 Total
Oklahoma CLE Approved 7 Total
Pennsylvania CLE Approved 6 Total
Rhode Island CLE Upon Request 7 Total
South Carolina CLE Approved 6 Total
Tennessee CLE Approved 6 Total
Texas CLE Approved 6 Total
Utah CLE Approved 6 Total
Virginia CLE Approved 6 Total
Vermont CLE Approved 6 Total
Washington CLE Approved 6 Total
Wisconsin CLE Approved 7 Total
West Virginia CLE Approved 7.2 Total
Wyoming CLE Approved 6 Total
Select Jurisdiction
CLE

Agenda

All times are shown in

  1. Get What You Need and Give Only What You Must

    1. Applying the Rules of Civil Procedure With Strategy in Mind
    2. Proportionality in Modern Discovery Practice
    3. Leveraging Local Rules, Standing Orders, and Scheduling Orders
    4. Designing a Plan and Strategically Sequencing Discovery
    5. Negotiating ESI Protocols and Protective Orders Early
    6. Preserving Evidence and Implementing Litigation Holds

  2. Interrogatories: From Boilerplate to a Strategic Tool

    1. Underused as a Strategic Tool and Overused as a Rote Exercise
    2. Contention Interrogatories: Timing and Tactical Value
    3. Drafting Techniques and Traps to Avoid
    4. Responding Strategically and Objection Tips
    5. Verification Requirements and Supplementation Duties

  3. Requests for Production: Winning the Document Battle

    1. Structuring Requests for Maximum Usability and Compliance
    2. ESI - The Modern Battlefield
    3. Metadata, Native Files, and Form-of-Production Traps
    4. Responding to RFPs: Strategic Objections and Partial Productions
    5. Privilege Logs Done Correctly - and Common Waiver Risks
    6. Inadvertent Production, Clawback Agreements, and FRE 502(d)

  4. Requests for Admission (RFAs): The Most Underutilized Discovery Weapon

    1. Strategic Value of RFAs: Narrowing Issues, Authenticating Documents, and Locking in Facts
    2. Advanced Drafting for RFAs
    3. Responding Effectively Without Making Unnecessary Admissions
    4. Deemed Admissions and Withdrawal Standards

  5. The Subpoena Arsenal (With Sample Language)

    1. Strategic Uses of Third-Party Discovery
    2. Drafting Effective Document and Deposition Subpoenas
    3. Phone, Social Media, and Other ESI Subpoenas: Unique Challenges and Solutions
    4. Subpoenaing Medical, Employment, and Financial Records
    5. Objections to and Motions to Quash Subpoenas
    6. Authenticating Third-Party Records for Trial

  6. Using AI to Transform Discovery Drafting and Review (With Demos)

    1. Moving from Boilerplate Requests to Precision Discovery
    2. AI Review Tools
    3. HIPAA, Confidentiality, and Data Privacy When Using AI in Discovery
    4. Discoverability of AI Prompts and Outputs

  7. Discovery Disputes, Motions to Compel, and Sanctions (With Sample Letters and Motions)

    1. Meet-and-Confer Requirements That Actually Matter
    2. Discovery Deficiency Letters
    3. Motions to Compel: Building the Record for Relief
    4. Protective Orders and Motions for Sanctions
    5. Rule 37 and ESI Spoliation Standards

  8. Ethics and Professional Responsibility in the Age of ESI and AI

    1. Duty of Competence in ESI and AI-Assisted Review
    2. Duty to Preserve Evidence
    3. Candor and Truthfulness
    4. Confidentiality and Privilege
    5. Fairness to Opposing Counsel and Parties
    6. Discovery Abuse and Sanctions

Who Should Attend

This program is designed for civil litigators at all experience levels. Paralegals and litigation support professionals who assist with discovery, document review, and motion practice may also benefit.

Speakers

Spencer M Aronfeld
Spencer M.
Aronfeld
Aronfeld Trial Lawyers
Christopher Campbell
Christopher
Campbell
DLA Piper
Richard K Leefe
Richard K.
Leefe
Leefe, Gibbs, Sullivan, Dupré, LLC
John L Tate
John L.
Tate
Stites & Harbison, PLLC
David A Lowe
David A.
Lowe
Keegan, Juban, Lowe & Robichaux, LLC
Speaker bio
Spencer M Aronfeld

Spencer M. Aronfeld

Aronfeld Trial Lawyers
Spencer Aronfeld

is a board-certified civil trial lawyer and the founder of Aronfeld Trial Lawyers, a Miami-based firm he established in 1991 after graduating cum laude from the University of Miami School of Law. Known for his work in personal injury and maritime law, Mr. Aronfeld has built a national reputation representing individuals against major corporations, including cruise lines and large manufacturers, and has achieved notable courtroom successes, including a widely recognized jury verdict against Walt Disney World. He is board-certified by both The Florida Bar and the National Board of Trial Advocacy, a distinction reflecting extensive trial experience and professional excellence. Mr. Aronfeld is also a frequent legal commentator featured on national media, a lecturer to lawyers and law students, and the founder of Lawyers to the Rescue, a nonprofit providing humanitarian and legal aid. He has been repeatedly named a Florida Super Lawyer and recognized as one of the “20 Most Intriguing Floridians,” underscoring both his legal achievements and community impact.

View full profile
Speaker bio
Christopher Campbell

Christopher Campbell

DLA Piper
Christopher Campbell

is a partner with DLA Piper. He is chair of DLA Piper's product liability and mass tort practice group. Mr. Campbell has 20 years of experience in all phases of mass tort, class action, and other complex commercial litigation, including trying cases and arguing appeals. He has served as global, national and trial counsel for many global companies in the life sciences, food and beverage, automotive and insurance sectors. In addition, Mr. Campbell advises clients on regulatory, communications and other strategic matters, with the potential to impact the clients' business interests or reputations. He earned his B.S. degree from Austin Peay State University and his J.D. degree from Harvard Law School.

View full profile
Speaker bio
Richard K Leefe

Richard K. Leefe

Leefe, Gibbs, Sullivan, Dupré, LLC
Richard Leefe

is a founder and senior partner of the Metairie law firm of Leefe, Gibbs, Sullivan, Dupré, LLC. Since 1974, he has practiced in the areas of commercial litigation and maritime law. Mr. Leefe has served as an adjunct professor for Loyola College of Law for more than 26 years, and has taught law school courses in evidence, negotiable instruments and legal research and writing. He also taught American law to Chinese law students in Wuhan, China. Mr. Leefe earned his B.S. degree from Louisiana State University; his L.L.M. degree from Robert Gordon University in Aberdeen, Scotland; and his J.D. degree from Loyola College of Law.

View full profile
Speaker bio
John L Tate

John L. Tate

Stites & Harbison, PLLC
John Tate

is a senior member of Stites & Harbison, PLLC and a fellow of the American College of Trial Lawyers. His national and regional litigation practice focuses on defending complex product liability lawsuits and managing serial litigation. Mr. Tate's extensive trial experience includes medical devices, pharmaceuticals, intellectual property, and a variety of personal injury matters. He has tried product liability cases to jury verdicts in eight states. Mr. Tate also maintains an active appellate practice representing appellees, appellants, and amici curiae in state and federal courts. He earned his B.A. degree from Wake Forest University; his J.D. degree, magna cum laude, from University of Louisville Louis D. Brandeis School of Law; and his M.A. degree from University of Louisville.

View full profile
Speaker bio
David A Lowe

David A. Lowe

Keegan, Juban, Lowe & Robichaux, LLC
David Lowe

is a partner with the law firm of Keegan, Juban, Lowe & Robichaux, LLC, where he focuses his practice in civil litigation, insurance bad faith, contracts, corporate matters, employment law, personal injury, and successions. He is admitted to practice before all state and federal courts in the state of Louisiana, and has been admitted to practice pro hac vice before multiple federal courts in other jurisdictions. Mr. Lowe has argued multiple cases before the U.S. Court of Appeals for the Fifth Circuit Court, as well as before the Louisiana Supreme Court. He is a member of the Baton Rouge, Louisiana State, Federal and American bar associations. Mr. Lowe earned his B.A. degree from the University of Southwestern Louisiana and his J.D. degree from Louisiana State University.

View full profile
Loading recommendations...

TOP FAQs

How do I access my courses?
Courses are available within your account. Simply login to your account and click on My Courses. If you require additional assistance please call our Customer Service Department at 800-930-6182.
Do you have options for attendees who are deaf or hard of hearing?
Closed captioning is available for all Live Webinars. After you've joined the event room, you can enable closed captioning by clicking the "cc" button in the lower right of the player.
What happens if my course is cancelled?
In the unlikely event that NBI cancels or reschedules an upcoming program, each registered attendee will be contacted via email by a representative of NBI. Outreach to attendees begins as soon as NBI is made aware that a program will not move forward at its originally scheduled date and time.
Are multiple attendee discounts available?
Yes, the more people you bring from your organization, the more you save. After the first registration, each additional attendee receives a special discount off of their total tuition.
When will the OnDemand be available and how long will I have access to the content?
The OnDemand Video will be available to stream within 7 days of live broadcast date. You will have access to the content for 6 months in your account. If you’re a subscriber, you’ll have access to your course recordings until 7 days after the expiration date of the subscription.
What is included with my course purchase?
When you enroll prior to the live event date you will receive access to the live-streaming webinar which will allow you to interact with faculty in real-time. With each course, you will receive access to the content via OnDemand Streaming and the Video Download. Course reference materials are included with each course purchase in a downloadable PDF format.
Will I receive a certificate of completion?
Yes, we'll email you a certificate of completion and store in your account for any future reporting needs.
Can multiple people watch courses and request credit?
While only paid registrants can receive continuing education credit for attending, there are no limitations to the number of viewers at each connection.

Have more questions? Please Contact Us