Draw up a document discovery agreement for plaintiff’s counsel

1. As defense counsel, draw up a document discovery agreement for plaintiff’s counsel. Is the language the same for both plaintiff and defendant? Explain.

2.Prepare the memo to the IT staff or outside consultant explaining what the trial team need in case of this type.

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3. Prepare the memo from the IT staff to the trial team explaining what issues they should be aware of and giving suggestions for obtaining and protecting the need data.

4. What role should attorney play in the preparation of interrogatories?

5. What guidelines should the attorneys in the office provide to the paralegals to help in preparing the interrogatories?

6. Who should be involved in the trial strategy discussions?

7. How should the final decision on presenting the case?

8. Who should make the ultimate decision on the presentation of the case in trial?

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