Stop Defense Obstruction: Dealing with Written Discovery and Protective Order Abuse - On Demand CLE

Morgan Adams

Format: On Demand Program
Sale price$100.00

Click here for Access Instructions for On Demand Programs.

Each attendee must register individually as they will need their own login to access the event and comply with CLE requirements.

Written discovery is critical. You need it to properly prepare for depositions, create or respond to motions, and arm or cross-examine experts. Yet reasonable discovery requests are often defeated by the defense’s obstructive tactics. Join Morgan Adams for a 60-minute program to learn how to deal with below-standard (BS) discovery objections and protective orders in federal and state court. 

In this program, Mr. Adams will cover:

  • Updated FRCP on discovery: the new “proportionality” test and the death of “not reasonably calculated to lead to the discovery of admissible evidence”
  • Proper sequencing of discovery
  • Improper discovery: omnibus terms in discovery such as “any and all facts”
  • Boilerplate objections, reservations of rights, and general and preliminary objections
  • Making proper objections and avoiding sanctions as a plaintiff (if you have not changed your standard objections since 2015, you may be subject to sanctions)
  • Dealing with the typical defense runaround:
    • Interrogatories
    • Request for production
    • “Subject to” and “without waiving”
    • Undue expense, burden, and oppression
    • Overbroad
    • Control
    • Work Product
  • Privilege logs
  • Standards for a proper “meet and confer”
  • Unsigned discovery
  • How to use the FRCP in your state court case
  • Don’t forget the burden! Improper requests for protective orders

Morgan Adams has successfully taken on cases against some of the nation’s largest trucking, bus, and insurance companies. Adams has worked on cases in 44 states and achieved record results in multiple states and jurisdictions. He has repeatedly been selected as a Super Lawyer, is a member of the Belli Society, Taos Group, Multi-Million Dollar Advocates Forum, AV rated by Martindale-Hubbell, 10/10 by AVVO, an AAJ Master of Trial Law Champion and a graduate of the Trial Lawyers College.

Need accreditation in another jurisdiction?  Fill out this form and note Course No. 211109D00

On Demand Program: 78 Minutes
Original Air Date: 12/02/2021

Approved and Pending Credits

Click Here

Accreditation Not Available


We will apply for accreditation in your state upon request. Please use the form at the bottom of the product description to request accreditation in your state.