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Requests for production, special interrogatories, and requests for admission are the backbone of civil discovery. Our February 2026 webinar, "Connecting the Dots with Written Discovery," featured amazing insight from Jessica Mederson (Attorney, Stafford Rosenbaum LLP), Kathleen McConnell (Partner, Seyfarth Shaw LLP), and Mindy Morton (Procopio, Cory, Hargreaves & Savitch LLP) on civil discovery.
Our “Connecting the Dots” conversation focused on best practices for lawyers to leverage all written discovery to identify the facts in a lawsuit. Every lawsuit is about answering the basic questions of who, what, when, where, why, and how. Written discovery is the tool to get those answers.
Both Kathleen McConnell and Mindy Morton stressed the importance of strategic planning when drafting discovery requests. Both attorneys stated they start with drafting requests for production and then use the RFPs to draft interrogatories.

Ms. McConnell shared that leveraging the jury instructions to draft discovery is very helpful in identifying the key factual issues for litigating a dispute.

Jessica Mederson shared how she uses requests for admission (RFAs) to narrow claims resolution in late-stage discovery. Ms. Mederson said, "I love them for summary judgment. They're great for determining factual disputes versus uncontested issues."
The panelists highlighted best practices for practicing law today, from AI tools to help draft interrogatories based on jury instructions, to requests for production strategies for metadata, to using all of written discovery to answer the core questions in a lawsuit.
Check out the webinar recording on-demand on the following link