Best Practices in Civil Discovery in Federal Court (2025 Edition)

Robert F. Redmond
Robert F. Redmond | McGuireWoods Consulting

Bob focuses his practice on mass tort, product liability and complex commercial litigation. He handles high exposure cases and jury trials in state and federal courts around the country. His trial experience includes first chair roles in product liability wrongful death cases for a major automobile manufacturer.

On-Demand: January 24, 2025

2 hour CLE

Tuition: $195.00
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Program Summary

This presentation is intended to address advanced topics in civil discovery within the federal system. It presupposes prior experience in written discovery and oral discovery, as well as pretrial procedure.

The presentation is divided into two general subject matter areas: Written Discovery and Oral Discovery. The materials are presented in a Frequently Asked Questions (“FAQ”) format that may be more accessible to seasoned practitioners.

Key topics to be discussed:

  • Written Discovery
    • Are “General Objections” Acceptable?
    • Do Parties Responding to Requests for Production Have an Obligation to Identify the Document Requests to Which the Documents Are Responsive?
    • How Do You Count Interrogatory Sub-Parts?
    • FRCP 33(d) and Specificity of Identification of Records
    • Can a Plaintiff Provide a Medical Record Authorization in Lieu of Producing Medical Records?
  • Oral Discovery
    • What to Do About Overbroad Corporate Deposition Notices
    • What Happens When a Corporate Representative “Does Not Know” about a Topic?
    • Can A Corporate Representative be Forced to Testify About Litigation Contentions?
    • Can a Deposing Party Demand the Documents Reviewed by the Corporate Witnesses in Preparation for Deposition?
    • Can You Consult with Your Witness During a Deposition?
    • What Are Proper Deposition Objections?

Closed-captioning available

Speakers

Robert F. Redmond_ McGuireWoods LLP._myLawCLERobert F. Redmond | McGuireWoods Consulting

Bob focuses his practice on mass tort, product liability and complex commercial litigation. He handles high exposure cases and jury trials in state and federal courts around the country.

He recently obtained the largest reported settlement in Virginia — $ 18.8 Million dollars — for The Brink’s Company in an insurance coverage matter against the London markets. The case was pending in the Eastern District of Virginia. His trial experience includes first chair roles in product liability wrongful death cases for a major automobile manufacturer. He was trial counsel in a multi-million-dollar Lanham Act and defamation jury trial in the U.S. District Court for the Eastern District of Virginia. The case resulted in the largest verdict in Virginia for that year. Less than a year earlier, he tried a multi-million-dollar tort case to a defense verdict also in the U.S. District Court for the Eastern District of Virginia. Additionally, Bob has tried CERCLA and mold toxicity cases to verdict in Virginia. He was trial counsel in a case selected by the National Law Journal as one of the “Top Ten Defense Verdicts of 2002,” and has served as counsel in numerous other jury trials around the nation.

Bob defends mass and class action defendants and has served as part of the national defense team for a consumer products retailer involved in formaldehyde-related class action litigation and a defendant in mass litigation involving tainted steroid injections. In addition, Bob maintains an active appellate practice. He has appeared as lead appellate counsel six times in the Supreme Court of Virginia and has argued in the Texas Supreme Court, the Texas Court of Appeals and the U.S. Court of Appeals for the Fifth Circuit. He has filed amicus curiae briefs in the U.S. Supreme Court on matters related to patent interpretation.

Bob also maintains an active pro bono practice. In 2005, Bob founded a pro bono clinic in conjunction with the Virginia Hispanic Chamber of Commerce to serve the needs of Hispanic immigrants. The Virginia State Bar and the City of Richmond Bar Association have recognized Bob’s work with their highest pro bono awards.

Prior to entering private practice, Bob was a prosecutor for the U.S. Army in the 82d Airborne Division at Fort Bragg, North Carolina.

T +1 804 775 1123 | rredmond@mcguirewoods.com

Agenda

I. Written Discovery | 2:00pm – 3:00pm

  • Are “General Objections” Acceptable?
  • Do Parties Responding to Requests for Production Have an Obligation to Identify the Document Requests to Which the Documents Are Responsive?
  • How Do You Count Interrogatory Sub-Parts?
  • FRCP 33(d) and Specificity of Identification of Records
  • Can a Plaintiff Provide a Medical Record Authorization in Lieu of Producing Medical Records?

Break | 3:00pm – 3:10pm 

II. Oral Discovery | 3:10pm – 4:10pm

  • What to Do About Overbroad Corporate Deposition Notices
  • What Happens When a Corporate Representative “Does Not Know” about a Topic?
  • Can A Corporate Representative be Forced to Testify About Litigation Contentions?
  • Can a Deposing Party Demand the Documents Reviewed by the Corporate Witnesses in Preparation for Deposition?
  • Can You Consult with Your Witness During a Deposition?
  • What Are Proper Deposition Objections?

Credits

Alaska

Approved for CLE Credits
2 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Approved for Self-Study Credits
2 General

Arkansas

Approved for CLE Credits
2 General

Arizona

Approved for CLE Credits
2 General

California

Approved for CLE Credits
2 General

Colorado

Pending CLE Approval
2 General

Connecticut

Approved for CLE Credits
2 General

District of Columbia

No MCLE Required
2 CLE Hours

Delaware

Pending CLE Approval
2 General

Florida

Approved via Attorney Submission
2.5 General Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Approved for CLE Credits
2 General

Hawaii

Approved for CLE Credits
2.4 General

Iowa

Pending CLE Approval
2 General

Idaho

Pending CLE Approval
2 General

Illinois

Approved for Self-Study Credits
2 General

Indiana

Approved for Self-Study Credits
2 General

Kansas

Pending CLE Approval
2 Substantive

Kentucky

Pending CLE Approval
2 General

Louisiana

Pending CLE Approval
2 General

Massachusetts

No MCLE Required
2 CLE Hours

Maryland

No MCLE Required
2 CLE Hours

Maine

Pending CLE Approval
2 General

Michigan

No MCLE Required
2 CLE Hours

Minnesota

Approved for Self-Study Credits
2 General

Missouri

Approved for CLE Credits
2.4 General

Mississippi

Pending CLE Approval
2 General

Montana

Approved for Self-Study Credits
2 General

North Carolina

Pending CLE Approval
2 General

North Dakota

Approved for CLE Credits
2 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
2 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
120 General Minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for Self-Study Credits
2 General

Nevada

Approved for Self-Study Credits
2 General

New York

Approved for CLE Credits
2.4 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Approved for Self-Study Credits
2 General

Oklahoma

Pending CLE Approval
2.5 General

Oregon

Pending CLE Approval
2 General

Pennsylvania

Approved for Self-Study Credits
2 General

Rhode Island

Pending CLE Approval
2.5 General

South Carolina

Pending CLE Approval
2 General

South Dakota

No MCLE Required
2 CLE Hours

Tennessee

Approved for Self-Study Credits
2 General

Texas

Approved for Self-Study Credits
2 General

Utah

Approved for Self-Study Credits
2 General

Virginia

Not Eligible
2 General Hours

Vermont

Approved for CLE Credits
2 General

Washington

Approved via Attorney Submission
2 Law & Legal Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Approved for Self-Study Credits
2 General

West Virginia

Pending CLE Approval
2.4 General

Wyoming

Approved for Self-Study Credits
2 General

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