Step 1 Review the scenario.

The senior attorney on the second floor of the office building had been a big help in advising attorney Owen Mason, based on his years of experience as a lawyer. He rarely tried any cases, at least not in the past 10 years. He approached Mason to personally request his paralegal's help with a case that had been filed in federal court. He had just received a discovery request involving Product Guild Limited (PGL), one of his biggest international clients. PGL was a paperless organization that stored everything electronically. There was a request for all the e-mails from the client for the past two years and all the corporate correspondence and a time deadline imposed by the rules of court. The senior attorney asked Mason if you could work for him as a part-time, independent paralegal to help handle this request. Mason agreed and asked you to begin working on this. (Note that this is similar for what you did for the previous assignment BUT should be information on how to REPLY to a discovery request. This is not a document to be served on the opposing counsel or filed with the court. Rather this is a memo to include information to provide to the senior attorney on how to handle the request.)

Step 2 Refer to the FRCP as necessary including the most recent amendments.

Use an Internet search engine to locate the Federal Rules of Civil Procedure (FRCP). See rules 26, 33, 34 and 37 specifically regarding discovery. You have probably completed this research already for the previous assignment.

Step 3 Write a memo to provide information on how to respond to the discovery request.

Write a memo to the senior attorney to provide him with information on how to respond to the discovery request described in the scenario in Step 1. Include the information that the legal team will need to gather for the requested documents and what else they will need to know in handling the discovery request from the opposing team. Answer the following questions in your memo based on the information provided in the scenario:

• Which documents are required by the Federal Rules of Civil Procedure to be provided to the opposing legal team under this request?
• How will the requested documents be gathered?
• What file format(s) will be used?
• How will confidential and privileged information be protected from disclosure? Are there any ethical considerations that should be addressed while reviewing or producing the information?