Facilitator Guide

Discovery Motions

Facilitator Guide

Discovery Motions

Topic: Motion Practice
Duration: 1 hr
Format: Remote or in person

What’s covered

What leads to discovery disputes
Meet and confer requirements
Motions to compel
Protective orders and motions to quash

Before the session

Prepare the Attendees

Send the attendees an invitation for the session. Include this link, which has the videos and exercise they’ll need to prepare.

https://www.hotshotlegal.com/trainings/discovery-motions/attendee

Prepare Yourself

Watch the videos and read the exercise so you’re familiar with the Hotshot material.

Course

Discovery Motions

Strategies and procedure for motions to compel, opposing motions to compel, and motions for a protective order. Discusses pre-filing requirements, drafting considerations, argument tips, and exhibits to include.
Exercise
PDF

During the session

Part 1: Knowledge Check

Ask attendees these questions to ensure they understand the topic:

What is the meet-and-confer requirement?
What legal standard does the court apply when deciding a motion to compel?
What are some ways that you can argue the discovery you’re seeking is relevant?
What are some ways to argue that the other side’s objections are baseless?
How does the legal standard differ when opposing a motion to compel versus moving for a protective order? What about motions to quash?
Why are proposed orders especially helpful in discovery motions?

Part 2: Group Exercise

Lead a group discussion based on the exercise. To encourage collaboration, divide the attendees into groups to discuss the exercise, then have a representative from each group summarize their views to the larger group. Call on people to share their thoughts and ask others to respond.

Tip for remote sessions: use your web conferencing system’s breakout room feature to divide people into groups.

Part 3: War Stories and Firm Specifics

Share your own experiences and guidance, including:

Anecdotes and war stories (e.g., about a near-disaster or a tough negotiation)
General practice tips (dos and don’ts)
Firm-specific guidance and practices

After the session

To continue their learning, attendees can check out related courses in Hotshot’s Motion Practice topic.

About Hotshot

Hotshot helps lawyers develop their legal, business, and technology skills through short videos, quizzes, and summaries, and we help law firms and law schools plan and deliver engaging training programs. Our customers include Am Law 200 firms, top law schools, and regional and international firms.