This task entails the development, response, objection, and negotiation of document requests, which includes participating in mandatory meet-and-confer sessions to resolve any objections. It also involves identifying documents for production, reviewing documents for privilege, coordinating the production process, and preparing privilege lists as requested. While this task involves a general review of documents produced by other parties, the specific coding and entry of produced documents into a database are categorized under Task L140. Moreover, if document review is mainly focused on understanding the facts, it falls under Task L110.

This category encompasses all tasks related to depositions, which include determining the deponents, scheduling the timing and sequence of depositions, preparing deposition notices and subpoenas, coordinating with opposing counsel or other parties on scheduling and logistics, planning and preparing for depositions, strategizing for depositions, witness preparation, reviewing documents for deposition readiness, attending depositions, and drafting deposition summaries.

This category corresponds to L330 but is specific to expert witnesses. It includes all tasks related to expert depositions, such as scheduling the depositions, preparing deposition notices and subpoenas for expert witnesses, coordinating with opposing counsel or other parties on deposition logistics, planning and preparing for expert depositions, discussing deposition strategy for expert witnesses, preparing the expert witnesses, reviewing documents for deposition preparation, attending expert depositions, and drafting any expert deposition summaries.

This task involves developing, responding to, and presenting all motions that arise from the discovery process. It also encompasses tasks related to the protective order process.

This category includes less commonly utilized forms of discovery, such as medical examinations and on-site inspections.