Best Practices in Civil Discovery in Federal Court (2025 Edition)

Robert F. Redmond | McGuireWoods Consulting

Bob focuses his practice on mass tort, product liability and complex commercial litigation. He handles high exposure cases and jury trials in state and federal courts around the country.

He recently obtained the largest reported settlement in Virginia — $ 18.8 Million dollars — for The Brink’s Company in an insurance coverage matter against the London markets. The case was pending in the Eastern District of Virginia. His trial experience includes first chair roles in product liability wrongful death cases for a major automobile manufacturer. He was trial counsel in a multi-million-dollar Lanham Act and defamation jury trial in the U.S. District Court for the Eastern District of Virginia. The case resulted in the largest verdict in Virginia for that year. Less than a year earlier, he tried a multi-million-dollar tort case to a defense verdict also in the U.S. District Court for the Eastern District of Virginia. Additionally, Bob has tried CERCLA and mold toxicity cases to verdict in Virginia. He was trial counsel in a case selected by the National Law Journal as one of the “Top Ten Defense Verdicts of 2002,” and has served as counsel in numerous other jury trials around the nation.

Bob defends mass and class action defendants and has served as part of the national defense team for a consumer products retailer involved in formaldehyde-related class action litigation and a defendant in mass litigation involving tainted steroid injections. In addition, Bob maintains an active appellate practice. He has appeared as lead appellate counsel six times in the Supreme Court of Virginia and has argued in the Texas Supreme Court, the Texas Court of Appeals and the U.S. Court of Appeals for the Fifth Circuit. He has filed amicus curiae briefs in the U.S. Supreme Court on matters related to patent interpretation.

Bob also maintains an active pro bono practice. In 2005, Bob founded a pro bono clinic in conjunction with the Virginia Hispanic Chamber of Commerce to serve the needs of Hispanic immigrants. The Virginia State Bar and the City of Richmond Bar Association have recognized Bob’s work with their highest pro bono awards.

Prior to entering private practice, Bob was a prosecutor for the U.S. Army in the 82d Airborne Division at Fort Bragg, North Carolina.

T +1 804 775 1123 | [email protected]

I. Written Discovery | 2:00pm – 3:00pm

• Are “General Objections” Acceptable?
• Do Parties Responding to Requests for Production Have an Obligation to Identify the Document Requests to Which the Documents Are Responsive?
• How Do You Count Interrogatory Sub-Parts?
• FRCP 33(d) and Specificity of Identification of Records
• Can a Plaintiff Provide a Medical Record Authorization in Lieu of Producing Medical Records?

Break | 3:00pm – 3:10pm 

II. Oral Discovery | 3:10pm – 4:10pm

• What to Do About Overbroad Corporate Deposition Notices
• What Happens When a Corporate Representative “Does Not Know” about a Topic?
• Can A Corporate Representative be Forced to Testify About Litigation Contentions?
• Can a Deposing Party Demand the Documents Reviewed by the Corporate Witnesses in Preparation for Deposition?
• Can You Consult with Your Witness During a Deposition?
• What Are Proper Deposition Objections?