For the next few days we will look at the Virtual Litigation Paralegal’s role in the discovery phase of any litigation file.

What is your discovery strategy for the litigation case at hand?  Your VLP will review the overall case strategy with you to set a timeline for completion of some specific discovery goals.

For most litigation files, the first stage of discovery begins with basic Interrogatories, Request for Admissions and Request for Production of Documents.  The VLP will help you establish basic forms to jump-start the discovery process of any litigation file covering specific areas of the Petition and Answer, identification of fact witnesses and expert witnesses, identification of relevant documents, production of all related documents including photos and electronic data.

The VLP can provide for your review an initial draft of Interrogatories, Request for Admissions and Request for Production of Documents.  She will help you finalize the discovery requests and serve on all parties of record.  The VLP will determine discovery response deadlines and help you monitor compliance with those deadlines by opposing counsel.  As needed, the VLP can contact opposing counsel by telephone to inquire when the discovery responses will be provided and document the communication.

If opposing counsel is uncooperative, the VLP can draft a Motion to Compel, contact opposing counsel to try to reach agreement, coordinate the filing of the Motion with the court and obtain a hearing date.  All parties will be notified and the hearing date will be docketed on your calendar.

The VLP can assemble all relevant documents into a digital hearing notebook file.   All you have to do is print the file and place it in your standard hearing notebook.  If you prefer, the VLP can complete that process and send the notebook directly to your office.

Next we will take a look at written responses to discovery requests.

For other posts in this series, visit Virtual Paralegal Series.

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