How to Manage Civil Discovery With a Paralegal

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    • 1). Verify that the paralegal understands her role in the discovery process. At the start of each case, have a meeting with your paralegal to determine what discovery tasks she is expected to perform.

    • 2). Maintain a log of incoming and outgoing discovery requests. To ensure that you are compliant with all discovery requests and to ensure that you have an opportunity to examine documents that the opposing counsel produces, create a log book. Your paralegal can maintain this log and list the date you receive discovery materials and the time and manner in which you send out discovery materials.

    • 3). Create a shared calendar for discovery deadlines. Merge calendars with your paralegal and create entries for discovery deadlines. Together, you can ensure that requests do not get overlooked.

    • 4). Utilize the paralegal's skills to make the best use of your work time. Allow your paralegal to handle document production and basic discovery tasks, such as creating boilerplate interrogatories, so that you can focus your time on in-depth research and trial preparation.

    • 5). Present your paralegal with professional development opportunities. To ensure that your paralegal stays up to date on federal and state rules, developments in the area of electronic discovery production and current trends in case management, encourage him to attend continuing legal education courses.

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