Pleadings and Discovery Requests for Paralegals


Re-Broadcast on December 15, 2016

This CLE provides an overview of the involvement of paralegals in the process of preparing pleadings and discovery. From initial case pleadings to start a litigation matter to the final appeals related briefs, paralegals are key in the preparation of these documents. Paralegals also play an important role in crafting discovery requests to opposing parties as well as assist with preparing proper and complete discovery responses.

Key topics to be discussed:

  • Preparation and elements of initial case pleadings
  • Exploration of the variety of discovery pleadings
  • Types of motions filed within an action
  • Review of appeals briefs and required components
  • Analysis of discovery requests and discovery responses

Date / Time: December 15, 2016

  • 2:00 pm – 4:00 pm Eastern
  • 1:00 pm – 3:00 pm Central
  • 12:00 pm – 2:00 pm Mountain
  • 11:00 am – 1:00 pm Pacific

Choose a format:

  • Live Video Broadcast/Re-Broadcast: Watch Program “live” in real-time, must sign-in and watch program on date and time set above. May ask questions during presentation via chat box. Qualifies for “live” CLE credit.
  • On-Demand Video: Access CLE 24/7 via on-demand library and watch program anytime. Qualifies for self-study CLE credit. On-demand versions are made available 7 business days after the original recording date.



MindiSchaefer_1Mindi L. Schaefer, M.S., RP, OSBA, AACP As Administrative & Paralegal Support Director, Mindi Schaefer is responsible for the management of the administrative and paralegal support staff which includes recruiting, training, work-flow coordination, productivity management, and continuing legal education. Additionally, she analyzes public relation and promotional strategies for the firm including sponsorship activities, pro bono opportunities, and speaking engagements. She researches print and electronic media options for the firm to promote and advertise the firm. In addition, Mindi focuses on social media implementation and website content management to maintain fresh and current firm content.

Mindi participates in various types of litigation cases in the areas of medical malpractice, dental malpractice, professional liability, general liability, governmental entity liability, business planning, and business disputes. She handles all aspects of the legal process including investigation, discovery, file management, and trial preparation. Through her work at Poling Law, Mindi works closely with clients, counsel, and the legal community to illustrate the firm’s belief in results, service, and relationships.
She received her Associates in Applied Sciences degree in Legal Assisting from Sinclair Community College in Dayton, Ohio in 1999. She received her Bachelor of Arts degree Cum Laude in Political Science from Wright State University in Dayton, Ohio in 2006. She received her Master of Science degree in Communications and Marketing from Franklin University in Columbus, Ohio in 2011.

Mindi received her Ohio State Bar Association Certified Paralegal status in 2010, American Alliance Certified Paralegal status in 2011, and National Federation of Paralegal Associations PACE Registered Paralegal status in 2013.

She actively participates in the Paralegal Association of Central Ohio (“PACO”) and presently holds the positions of President of the Executive Board, Advisory Board Chair, Professional Development Chair, and National Federation of Paralegal Associations (“NFPA”) Secondary Representative/Statewide Representative.

Mindi has received numerous awards from the Paralegal Association of Central Ohio including Outstanding Committee Chair for 2009 to 2010, Ten Year Paralegal Service Award in 2009, Outstanding Member for 2010 to 2011, Paralegal of the Year 2011 to 2012, Paralegal of the Year 2012 to 2013, and Fifteen Year Paralegal Service Award in 2014.

She is a continuing legal education presenter with the Columbus Bar Association (“CBA”), NFPA, myLawCLE, and Institute for Paralegal Education focusing on the areas of case preparation from start to Trial and document management. Mindi has been a featured author with the Columbus Bar Friday Paper (affiliated with The Daily Reporter / CBA), PACO, and National Paralegal Reporter (affiliated with the NFPA) focusing on topics associated to paralegals, PACO, employment, mentoring, and trial preparation. She is also a frequent guest speaker at Capital University Law School, Columbus State Community College, ITT Technical Institute, Miami-Jacobs Career College, and local area high schools focusing on interviewing, entering the paralegal profession, and the overall paralegal profession in Central Ohio.

Mindi’s professional associations include Ohio State Bar Association, Notary Public for the State of Ohio, National Federation of Paralegal Associations, American Alliance of Paralegals, Inc., Columbus Young Professionals, Columbus Bar Association, Paralegal Association of Central Ohio, Miami-Jacobs Career College Paralegal Advisory Board, Columbus State Community College Paralegal Advisory Board, Franklin University Alumni Association, Wright State University Alumni Association, Sinclair Community College Alumni Association, Social Media Club of Columbus, International Paralegal Management Association, Claims & Litigation Management Alliance (Fellow Member), and Paralegal Knowledge Institute.

AthenaDYontz_1Athena D. Yontz is a litigation paralegal at a litigation law firm in Columbus, Ohio. She has over seventeen years of experience working in the legal field as both an administrative assistant and paralegal. Her legal experience includes medical malpractice, legal malpractice, social security, criminal, personal injury, and general litigation defense. Athena’s duties have included legal research, investigation, discovery, file management, trial preparation, medical record review and summary, billing review and summary.

Athena’s educational background including her 2002 Bachelor of Science in Business Administration degree from Franklin University in Columbus, Ohio and her 2007 Master of Business Administration degree from Franklin University in Columbus, Ohio.

Athena also serves as a senior paralegal mentor to paralegal students through the Paralegal Association of Central Ohio’s (PACO) Mentoring Program which she chairs. She is also the PACO Treasurer for the Executive Board. Athena’s professional associations include PACO, Columbus Bar Association, National Federation of Paralegal Associations, Ohio State Bar Association, Franklin University Alumni Association, and Notary Public for the State of Ohio.

myLawCLE does not seek approval for all Paralegal Training courses with individual State Bars. However, myLawCLE does seek approval for such courses with the National Association of Legal Assistants (NALA) and National Federation of Paralegal Associations (NFPA).

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myLawCLE offers a program and credit approval guarantee. If a registered attendee is unhappy with a CLE program they have attended, myLawCLE will offer that attended access to another complimentary CLE or a full refund in order to insure the attendee is satisfied.

Additionally, on all online CLE programs application for approval will be made in all states where attending attorneys are primarily licensed in. If a registered attorney does not receive credit from their state for any reason, a full refund will be granted.

Pleadings in All Forms (1.25)

Section I. Initial Case Pleadings

a) Court Rules
b) Complaint
c) Parties
d) Jurisdiction
e) Facts
f) Prayer
g) Jury Demand
h) Service
i) Standard Defenses
j) Answer
k) Cross-Complaint
l) Cross-Claim
m) Counter-Claim

Section II. Discovery Pleadings
a) Court Rules
b)Factual Pattern
c)Case Law
d) Due Dates
e) Motion to Dismiss
f) Motion for Summary Judgment
g) Motion in Limine
h) Motion to Compel
i) Motion for Sanctions
j) Motion for Continuance
k) Motion for Change of Venue
l) Motion in Support vs. Motion in Opposition
m) Elements of Motion Practice

Section III. Briefs
a) Court Rules
b) Due Dates
c) Forms and Format Requirements
d) Trial Briefs
e) Appellate Briefs

Discovery: From Requests to Responses (0.75)

Section IV. Drafting Discovery
a) What Questions to Ask
b) What Items to Request
c) Court Rules
d) Preparing Responses
e) General Objections
f) Supplementation of Responses
g) Red Flags
h) Incomplete Responses from Opposing Counsel
i) Requests for Admission