Scope and Application of Rule 34: Effective document requests for modern litigators

Adam Gutbezahl
Adam Gutbezahl | Ruberto, Israel & Weiner, P.C.

Adam Gutbezahl is an attorney at the Boston-based law firm Ruberto, Israel & Weiner, P.C. and is a member of the firm's litigation department and commercial real estate and employment law groups.

On-Demand: November 20, 2024

2 hour CLE

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Program Summary

Obtaining relevant, responsive documents during discovery is an essential aspect of litigation. In order to ensure that a party obtains the information necessary to support its claims or defenses, it is key that lawyers maximize the use of document requests served under Rule 34 of the Massachusetts Rules of Civil Procedure. This session will explore the intricacies of crafting effective document requests, including the scope and timing of requests, resource allocation considerations, and best practices for responding to non-compliant productions. Participants will gain practical insights and techniques to enhance their discovery practices and navigate the complexities of federal litigation with confidence.

This course is co-sponsored with myLawCLE.

Key topics to be discussed:

  • Understanding the scope and application of Rule 34
  • Determining best practices for when to serve document requests and how to align them with case timelines
  • Crafting specific, yet comprehensive, requests, including obtaining electronically stored information
  • Addressing practical steps for responding to inadequate document production and enforcing compliance

Closed-captioning available

Speakers

Adam Gutbezahl_MyLawCLEAdam Gutbezahl | Ruberto, Israel & Weiner, P.C.

Adam Gutbezahl is an attorney at the Boston-based law firm Ruberto, Israel & Weiner, P.C. and is a member of the firm’s litigation department and commercial real estate and employment law groups. Adam represents both individuals and businesses in a wide variety of matters, including complex commercial, employment, land use, and real-estate disputes. With his client-driven focus, Adam understands how to translate the concerns of his clients into practical solutions that make sense for their individualized needs. In addition to handling contentious, high-stakes cases in Massachusetts state and federal courts, Adam counsels his clients on the importance of developing best practices to avoid litigation and mitigate risks.

Adam is a recognized thought leader on the legal implications of Generative Artificial Intelligence (“Gen AI”). He has been a featured speaker for numerous associations and organizations on the topic of Gen AI, including its legal and practical effects on the workplace and in the legal profession and has written extensively on the topic. Adam is a member of multiple steering committees concerning Gen AI, including the Privacy, Security & Digital Law Group within the Boston Bar Association and the Artificial Intelligence Task Force for the Massachusetts Real Estate Bar Association.

Adam is a member of multiple organizations, has held, and continues to hold elected positions. He is also a member of the Wayland Trust Fund Commission, on which he has served since 2019, as well as a former member of the Wayland Select Board, on which he served from May 2021 through May 2024. The New England Real Estate Journal identified Adam in its 2024 Ones to Watch – Rising Stars list and Super Lawyers listed Adam as a Rising Star in 2024. He was also selected to participate in the Boston’s Future Leaders Program in 2024, which is a 10-month leadership initiative by the Harvard Business School and the Greater Boston Chamber of Commerce. Adam received his J.D., cum laude, from George Washington University Law School, where he was a member of the Moot Court Board and an executive editor of The George Washington Law Review.

Agenda

I. Understanding the scope and application of Rule 34 | 2:00pm – 2:30pm

II. Determining best practices for when to serve document requests and how to align them with case timelines | 2:30pm – 3:00pm

Break | 3:00pm – 3:10pm

III. Crafting specific, yet comprehensive, requests, including obtaining electronically stored information | 3:10pm – 3:40pm

IV. Addressing practical steps for responding to inadequate document production and enforcing compliance | 3:40pm – 4:10pm

Preview
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