Today we will continue looking at the Virtual Litigation Paralegal’s role in the discovery phase of any litigation file.  Specifically, we will examine the VLP’s role concerning written responses to discovery requests and document management.

Your VLP will monitor all discovery deadlines and notify you immediately if opposing counsel fails to answer discovery in a timely fashion. Following your lead, the VLP can contact opposing counsel in an attempt to resolve the issue and draft written notice that a Motion to Compel will be filed if counsel continues to ignore the discovery requests.

If necessary, your VLP will review local rules concerning motion requirements related to discovery matters and then draft a Motion to Compel.  The VLP can coordinate the filing of the motion, obtaining a hearing date and providing notice to opposing counsel.

As written responses are received to interrogatories, requests for production of documents and requests for admission, your VLP will assist you in a thorough review to be certain that complete responses have been received.  It is likely that the discovery responses will contain at least some objections.  Your VLP can summarize the objections and help you draft correspondence to opposing counsel seeking resolution.  This is particularly important if the responses contain numerous objections when it becomes helpful to chart the objection resolution process.  If the parties are unable to resolve the matter, a Motion for Hearing will be prepared and filed with the Court.

During the review process, your VLP will continue to update witness and exhibit lists.  Your VLP will also monitor case privilege logs for all parties.  It is important that this task is not ignored.  In the very least, you can list groups of documents received and expand the list for specific exhibits at a later date.  A more detailed discussion of document management will be handled in a separate posting.

Your VLP will again review discovery strategy with you to determine when you will want to proceed with your second wave of follow-up written discovery requests.  The VLP will outline additional areas to be addressed in future discovery requests and begin the drafting process.

Check back soon for Discovery, Part 3, which will examine the deposition phase of the discovery process.

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

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