Discovery Requests (4 or 4)

The #BigLaw partner (or senior associate) asked you to draft discovery requests.

You've reminded yourself what written discovery is all about.

You've pulled together the contextual documents and samples.

You've checked in with the partner, confirming the themes and strategy.

Now, you're ready to draft.

✍ Create the template (case caption, opening lines, instructions, definitions) or have a supporting team member create it. This shell is your canvas. I like to start here.

✍ Go overboard. Consider your first draft a brain dump. Have no regard for order, just get your ideas on the page. Draft as many requests as you can come up with.

✍ Put the draft down. Walk away. For an hour, a night, a day.

✍ Return to the draft with fresh eyes, not just to revise, but to cull down the requests and reorder them.

✍ Repeat. Walk away from the draft and come back (as many times as you need or have time for). Maybe this time, ask yourself, if you were in the other party's shoes what would you hope to not be asked about?

✍ When ready, submit for internal review.

To do this best, you'll need to create time, working backwards from the external and internal deadlines.

With adequate time, you can have someone senior (but not the supervisor) look at it before you submit it to the partner.

We can talk about feedback later--which you should request and expect. There will likely be a lot of it on your first few drafts of discovery requests. That's okay--we've all been there.

Discovery is nuanced. It is an art. As a #BigLaw litigation associate, you'll spend most of your time here--and be an expert, ready to teach those following you in no time.

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