Brand new baby lawyer dumb question - I am tasked with drafting response to request to produce. How long should this take? And follow up… how do I bill this?

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Typically 2-6 hours. "Draft responses and objections to Requests for Production from ___". Save yourself some time and ask a mid level for samples

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Yes definitely get a template - don’t start from scratch!

As long as it takes (there’s no standard time). I had ones that I did in an hour and others that took a week.

“Work on responses to discovery requests”

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Well of course you bill it you dummy. Bill all your time!

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(Ethically) bill all your time. Do not worry if it took you too long because you don’t know how. It’s the partner’s job to cut excessive time for the client. It’s the firm’s job to train you, and part of that incorporates the fact that they won’t be able to bill a client for 100% of your time and that you’re not as productive as a more senior attorney

As a new attorney I would not worry much about the time you’re taking on a task, as much as just doing it right (unless the supervising attorney explicitly asks you to keep time down). Avoid spinning your wheels, spending time on clerical things you can assign to a paralegal/secretary, and ask questions when you’re truly stumped. Otherwise, you’re probably just fine on time and the partner will adjust the bill if it’s really outrageous (most of the time it’s not).

The amount of time it will take depends in part on how many requests there are and certain other things, such as whether you need to do any research to determine any valid objections and the applicable procedural rules (e.g., if a request seeks certain expert materials that can’t be requested through an RFP) and whether you need to review any client documents in connection with shaping the response. For example, if an overly broad request asks for X, Y, and Z, we might object to X entirely, provide Y, and say that after a reasonable search, there are no Z documents. We try to tailor our objections/responses for each request and don’t just copy/paste boilerplate objections to everything. I’d expect it to take you at least a few hours, and it wouldn’t be abnormal to take longer than that.

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