Taking the deposition of persons who have been designated to testify on behalf of a defendant are a critical component of a class action discovery plan. These “corporate designee” or “Person Most Knowledgeable” depositions under FRCP 30(b)(6) deposition or CCP section 2025.230 can make or break your case for class certification. These witnesses are your opportunity to get testimony that binds the corporate defendant and which, hopefully, proves that the policy, procedure or practice challenged in your class case uniformly affects the class.
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Today, numerous documents are created, and/or are delivered electronically. Documents that are relevant to issues in litigation raise questions such as how to access them through discovery procedures, and how to introduce discovered electronic evidence at trial. Hence, it is important for attorneys to work with paralegals to devise efficient ways of organizing, storing, and, managing documents. Electronic case documents are much easier to handle than hard copy productions – and less burdensome. In the following paragraphs, I will offer suggestions for organizing, storing, and managing electronic document productions from inception of a case to the end of the period of discovery.
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While high-profile summer associate positions at large defense firms garner thousands of applications every year based solely on the fact that they are paying exorbitant amounts of money, the vast majority of law students seek an experience that is equally, if not more valuable in terms of advancing their legal career. As evidenced by the high number of law students taking non-paying positions clerking for Federal and State justices and government agencies, law students will spurn more lucrative opportunities in order to gain high quality experiences they perceive as valuable to their pursuit of success in the legal profession.
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