What’s your favorite discovery tool and why? I’m a second year associate and trying to get better at prosecuting cases in commercial litigation.

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Each type of discovery has its own strength. Start with gathering evidence using interrogatories and requests for production. Subpoena duces tecum. Once you have digested that information, make a list of potential witnesses. Decide which documents are exhibits or useful for deposition purposes. Bates stamp. Create Chronology of documents. Determine who is at the top of the list. You and your supervising partner decide who to depose. With information you learn at deposition, rinse and repeat.

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This is the way. I like to hold off on issuing ROGs, if possible, until I’ve first issued doc requests and received responsive docs, so that I can better tailor my ROGs

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Everlaw. Good user interface and generally faster compared to something like Relativity.

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Following.

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