Mastering Written Discovery: Interrogatories, Document Requests, and Admissions That Win

Reuben A. Guttman, Senior Founding Partner | Guttman Buschner PLLC

Reuben A. Guttman is a founding member of Guttman Buschner LLP in Washington, D.C. His practice centers on complex litigation, class actions, fraud, antitrust, and False Claims Act cases. Over his career, he has litigated and tried cases resulting in significant whistleblower recoveries. He is widely recognized as one of the country’s foremost False Claims Act and whistleblower attorneys. In addition to his practice, Mr. Guttman teaches trial advocacy and contributes scholarship on legal and public policy issues.

• Education & Credentials
  • Reuben A. Guttman earned his Juris Doctor from Emory University School of Law in 1985 and received a Bachelor of Arts in American History from the University of Rochester in 1981. In addition to practicing law, he serves in academic roles including as a Senior Fellow and Adjunct Professor at the Emory University School of Law Center for Advocacy and Dispute Resolution, where he teaches and participates in trial advocacy training programs.
• Recognition & Leadership
  • Mr. Guttman has been recognized within the legal profession for his work in whistleblower and complex litigation matters. Media coverage and legal publications have described him as a leading attorney in whistleblower litigation, and he has been named a “Top Lawyer” by Washingtonian Magazine. He has also served in leadership roles in legal and policy organizations, including election to the Board of Directors of the American Constitution Society for Law and Policy, and has participated in national and international programs focused on advocacy and legal training.
• Professional Involvement
  • Beyond his litigation practice, Mr. Guttman is actively engaged in legal education and scholarship. He has lectured domestically and internationally, including at universities in China and through U.S. State Department programs training judges and practitioners in trial advocacy. He has also contributed commentary and articles on law, governance, and public policy.
• Experience
  • Mr. Guttman’s practice spans complex commercial disputes, class actions, and whistleblower cases involving government fraud and regulatory violations. He has served as lead counsel in major False Claims Act matters, securing significant recoveries in pharmaceutical and financial fraud settlements. His work has addressed unlawful drug marketing, fraudulent mortgage assignments, and government contracting misconduct. He has also litigated employment and labor matters, including federal labor standards, workplace safety, and cases affecting workers in the U.S. nuclear weapons complex.

Whitney M. Untiedt, Co-founder Partner | Untiedt Dabdoub

Whitney M. Untiedt is a trial attorney and co-founder of Untiedt Dabdoub & Tyler in Coral Gables, Florida, where she leads the firm’s trial practice. She represents victims of medical malpractice, brain and birth injuries, wrongful death, and complex civil litigation throughout Florida and across the country. Known for her meticulous approach, Whitney plays an active role at every stage of a case from pre-suit investigation through trial or settlement and is deeply committed to achieving justice for her clients and their families.

• Education & Credentials
  • Whitney is Board Certified in Juvenile Law by The Florida Bar and is admitted to practice in the U.S. District Courts for the Southern and Northern Districts of Florida, the U.S. Courts of Appeals for the Eleventh and Eighth Circuits, and the U.S. Immigration Court. She has taught at the University of Florida Levin College of Law and the Warrington College of Business.
• Recognition & Leadership
  • Whitney has earned sustained recognition among Florida’s most accomplished trial attorneys. She has been named to Best Lawyers in America (Personal Injury Litigation, 2023–present), Super Lawyers (2020–present), and Florida Trend Legal Elite Civil Trial (2018–present). Her trial victories include recognition in Top 100 Verdicts in Florida (2022) and Top 50 Wrongful Death Verdicts (2021). Earlier honors include the Daily Business Review’s 2016 Lawyer of the Year, the National Law Journal’s 2018 Pro Bono Hot List, the American Immigration Lawyers Association’s 2019 Arthur C. Helton Memorial Human Rights Award, and the Advocates for Human Rights 2019 Human Rights Volunteer Award.
• Professional Involvement
  • Whitney is a Trustee for the National Institute for Trial Advocacy (NITA) and has trained thousands of attorneys across the U.S., Europe, and Africa as a NITA faculty member. She serves on the boards of the American Constitution Society’s South Florida chapter and Planned Parenthood of South, East, and North Florida. Within The Florida Bar, she holds leadership roles on the Trial Lawyers Section Executive Council and the Code & Rules of Evidence Committee and served as Co-Chair of the 2023 Florida Bar Annual Convention.
• Experience
  • Before founding Untiedt Dabdoub & Tyler, Whitney served as a trial lawyer at a premier boutique litigation firm, as national pro bono partner at an AmLaw 100 firm, and as a managing attorney at a Florida public defender’s office. Her published work includes articles in Law360, the Florida Bar Journal, and academic journals, as well as the widely cited piece Carroll v. Trump: A Case Won in Pretrial (NITA, 2023). Her career reflects a consistent commitment to complex civil litigation, appellate practice, public service, and the advancement of the legal profession.

Traci L. Buschner, Founding Partner | Guttman Buschner PLLC

Traci L. Buschner is a founding partner of Guttman Buschner LLP in Washington, D.C., and one of the country’s foremost whistleblower and False Claims Act attorneys. With nearly 30 years of experience representing plaintiffs in complex litigation, she has played a leading role in some of the largest government fraud recoveries in U.S. history bringing billions of dollars back to the federal government through landmark pharmaceutical and healthcare fraud cases.

• Education & Credentials
  • Ms. Buschner received her J.D. from the University of Louisville and her undergraduate degree from Miami University. She is admitted to practice in the District of Columbia, the Commonwealth of Kentucky, the U.S. District Court for the District of Columbia, the District of Maryland, and the Western District of Columbia, and the U.S. Courts of Appeals for the District of Columbia Circuit and the Ninth Circuit. She is a Fellow of the American Bar Foundation.
• Recognition & Leadership
  • She served as President of the Trial Lawyers Association of Metropolitan Washington, D.C. (TLA-DC) from 2024–2025 and as Chair of the Miami University Alumni Pre-Law Advisory Board (2022–2024). Ms. Buschner has been recognized by Washingtonian Magazine as a top Whistleblower Lawyer for several consecutive years and was named to the National Law Journal’s Plaintiffs’ Hot List (2011–2012) for her work on the landmark Abbott Laboratories False Claims Act case.
• Professional Involvement
  • Ms. Buschner is a member of the American Association for Justice (AAJ). She has served as faculty for Emory University Law School’s Trial Techniques Program (2011, 2012, 2014, and 2016) and is an active voice in the legal community on issues of pharmaceutical fraud, corporate accountability, and civil litigation. She has co-authored articles published in the Wall Street Journal MarketWatch and the American Constitution Society Blog, and her work exposing faulty government contracting at Department of Energy nuclear weapons sites was published in The Environmental Forum.
• Experience
  • Before co-founding Guttman Buschner LLP, Ms. Buschner served as a state prosecutor and p a trial lawyer at major litigation firms in Washington, D.C. and Austin, Texas. Her False Claims Act practice has produced some of the most significant recoveries in the history of the statute, including cases against Pfizer ($2.3 billion), GlaxoSmithKline ($1.04 billion), Abbott Laboratories ($1.5 billion), and Wyeth Pharmaceuticals ($257.4 million).

SESSION 1 – Framing Written Discovery to Generate Admissible Evidence | 1:00pm – 1:20pm

Learn to draft interrogatories, document requests, and admissions with evidentiary purposes structuring each request to produce responses that qualify as admissible evidence at trial under the Federal Rules.

SESSION 2 – Framing Written Discovery for Motions Practice | 1:20pm – 1:40pm

Discover how to use interrogatories, document requests, and admissions strategically to build the factual record needed to support or defeat dispositive motions, including summary judgment and motions in limine.

SESSION 3 – Procedural & Evidentiary Framework for Discovery-Based Evidence | 1:40pm – 2:00pm

Master the procedural rules and evidentiary standards including FRE 401, 403, 404, 801, 803, 901, 902 and 1006 required to successfully introduce evidence obtained through written discovery into the litigation record.

BREAK | 2:00pm – 2:10pm

SESSION 4 – Using Written Discovery at Trial | 2:10pm – 2:40pm

Learn how interrogatory answers, document productions, and admitted facts function as trial evidence and how to authenticate, introduce, and leverage them effectively before a judge or jury.

SESSION 5 – Using Written Discovery to Pierce Privilege Assertions | 2:40pm – 3:10pm

Develop targeted strategies for using interrogatories and document requests to challenge inadequate privilege logs, expose waivers, and compel production of documents improperly shielded from discovery.