Best Practices in Civil Discovery in Federal and Virginia State Courts (On Demand Seminar)

MCLE Credits: 2.0
Ethics Credits Included: 0.0

MCLE Credit: 2.0 (Ethics: 0.0)
Live-Interactive Credit: 0.0
Designation Credit: 2.0 Trial Practice/Litigation (Designations Information)
Price: $149 (Includes a downloadable audio version.)
Viewable Through: 08/31/2023


A pre-recorded streaming video replay of the July 2020 webcast, Best Practices in Civil Discovery in Federal and Virginia State Courts.

Topics Covered

  • Learn best practices during the discovery phase of complex litigation from an experienced plaintiffs’ lawyer and an experienced defense lawyer
  • Examine both written and oral discovery
  • Receive a downloadable, heavily annotated set of program materials

Intended for seasoned litigators and presupposing attendees’ experience in written and oral discovery in state and federal courts in Virginia (and elsewhere), this program will address recurring issues in the discovery phase of complex litigation. It will draw from an extensive review of state and federal precedent (over 100 cases). Participants will receive a heavily annotated 46-page packet of program materials.

This program is both broad and balanced, presented by an experienced plaintiffs’ lawyer, Doug McNamara of Cohen Milstein, and an experienced defense lawyer, Bob Redmond of McGuireWoods LLP. The speakers will address 25 separate topics, including:

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?
  • Can you require a verified statement that the responding party has searched for responsive documents under Rule 4:9 and FRCP 34?
  • Can a responding party cite to government or non-party records in answer to interrogatories under Rule 4:8(f) or FRCP 33(d)?
  • Are unverified interrogatories timely?

Oral Discovery:

  • What to do with 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?
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Douglas J. McNamara, Cohen Milstein / Washington, DC
Robert F. Redmond, McGuireWoods LLP / Richmond


Douglas J. McNamara, Cohen Milstein / Washington, DC
Doug McNamara is a partner at Cohen Milstein, and a member of the firm’s Consumer Protection practice group. In this role, Mr. McNamara specializes in litigating complex, multi-state class action lawsuits against manufacturers and consumer service providers, such as banks, insurers, credit card companies, and others.  He has helped litigate precedent-setting cases, involving issues of preemption, choice of law, and class certification. He is a hands-on litigator who takes pleasure in the details, facts, and documents of each case. Mr. McNamara is a highly regarded speaker who has presented at several forums on such topics as federal preemption, class certification, and civil litigation, and is the author of scholarly articles focusing on emerging legal issues.

Robert F. Redmond, McGuireWoods LLP / Richmond
Bob Redmond has been practicing law for over thirty years. He focuses his practice on mass tort, product liability, and complex class action litigation. He tries jury cases to verdict in state and federal courts around the country. In addition, Mr. Redmond  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 Firth Circuit. Mr. Redmond also maintains an active pro bono practice. In 2005, he 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 his work with their highest pro bono awards. Prior to entering private practice, Mr. Redmond was a prosecutor for the U.S. Army in the 82nd Airborne Division at Fort Bragg, North Carolina.

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