Facilitator Guide

Discovery Requests and Responses & Objections

Facilitator Guide

Discovery Requests and Responses & Objections

Topic: Civil Litigation Basics
Duration: 1 hr
Format: Remote or in person

What’s covered

Types of discovery requests
Drafting requests for production
Drafting interrogatories
Drafting requests for admission
Common responses and objections
Responses and objections based on type of request

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-requests-and-responses-objections/attendee

Prepare Yourself

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

Course

Discovery Requests

Lawyers use requests for production, interrogatories, and requests for admission to get different types of information during discovery. This course explains these discovery requests, including what sections appear in typical requests and related drafting tips.
Course

Discovery Responses and Objections

After receiving a discovery request, a party will prepare written responses and objections. This course explains written responses and objections to document requests, interrogatories, and requests for admission.
Exercise
PDF

During the session

Part 1: Knowledge Check

Ask attendees these questions to ensure they understand the topic:

Describe the three types of discovery requests.
Can you make an unlimited number of discovery requests?
What are in the preliminary portions of a discovery request?
What are some things to keep in mind when drafting requests for production?
Why is it helpful to review the pleadings and motions in a case when drafting discovery requests?
What are some ways that interrogatories can be useful?
What are some tips for drafting requests for admissions?
What’s the purpose of responses and objections?
Name and describe a few common objections.
What are some things to keep in mind when preparing Rs and Os for:
- Requests for Production
- Interrogatories
- Requests for Admission

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 Civil Litigation Basics 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.