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Rising Star
Wait a few years until you’re more senior and have the more junior people handle discovery. Problem solved. 👍
Now seriously, get written responses out, collect easy things that aren’t a big deal and don’t fight unnecessary fights. Very little actually matters in discovery.
Rising Star
Unfortunately much of discovery has more to do with posturing and running up a bill than getting info you need to try the case (or get SJ).
You need to focus on getting the basic responses done in time or within an agreed upon extension. Then continue with fighting over the sufficiency of the responses and production. That usually helps with not missing a deadline or being sick to your stomach.
Send discovery requests to your opposing counsel the day you are allowed to under the federal or state or local rules. Ideal hands do the devil‘s work. Give the asshole on the other side a task so that they are worrying about deadlines.
Yes, I hate doing discovery. But I have learned that being organized at the front end can make discovery much less daunting. You should develop a process for getting discovery to the client right away, and giving them a deadline to get responses back and documents. Rely heavily on your legal assistant if you can. Take some time to learn the proper scope of objections and how to phrase them. Make sure the client knows how to answer them and have good boilerplate instructions so your life is easier. Discovery is not fun. However, there is a process than you can develop at the start to make sure it stays organized. Also, from my experiences, it is hard to get discovery responses done in 4ish weeks. More often than not I am asking for extensions and so is opposing counsel.
And anticipate what documents and information you will need prior to filing a responsive pleading. Get the documents at that point as well as interviews with relevant witnesses so that you are just going back to the client to fill in the blanks. Also, treat it like a scavenger hunt and set an internal deadline. Put a realistic estimate in your response: “defendant estimates that it will take 7 weeks to run search terms on email accounts and conduct review for responsiveness and privilege/work product.”
Glad I'm not alone.
Become a transactional attorney.
How do you eat an elephant? One bite at a time. Break it down into tasks and schedule each task on your calendar. With enough time to get that task done.
I would like to find a person who likes discovery.
I just power through but wish it didnt take so long. Literally like 8+ or more hours to draft objections/responses, identify responsive docs, correspond with clients to rfas, rfps, and rogs.