With more than 25 years at Shook, Steve has extensive experience successfully helping several Fortune 500 consumer products companies and pharmaceutical manufacturers with the legal and practical issues associated with the pre-trial and discovery-related aspects of complex, nationwide product liability litigation. This includes many class actions and multi-district litigations involving multi-million-dollar damages claims. Steve also advises clients regarding case law and state and federal procedural rules governing discovery in civil cases, as well as the law of attorney-client privilege and the attorney work-product doctrine.

Steve’s experience on behalf of Shook clients includes:

Privilege and Work Product Issues

  • Reviewing client documents and ESI for application of the attorney-client privilege and work-product doctrine
  • Drafting and editing privilege review guidelines and protocols
  • Drafting, reviewing, and finalizing privilege logs (domestic and international)
  • Establishing practical and cost-effective processes for privilege review and managing privilege review teams, including third-party vendors

Confidential and Proprietary Information Issues

  • Assisting in the drafting and negotiation of protective orders and discovery protocols
  • Reviewing client documents and ESI for confidential and proprietary information 
  • Managing the review of deposition transcripts and exhibits for confidential and proprietary information

Discovery Requests

  • Managing the collection and review of client documents and ESI for responsiveness to Requests for Production
  • Drafting responses to Requests for Production, Interrogatories, and Requests for Admission
  • Assisting case teams with analysis of issues related to Plaintiff Fact Sheets
  • Managing the preparation of Defendant Fact Sheets and assisting case teams with related issues
Discovery Disputes and Motions
  • Supporting case teams in “meet and confers” with opposing counsel on discovery issues
  • Assisting case teams with responses to deficiency letters and motions to compel
  • Drafting memoranda in defense of privilege claims in response to motions to compel production of privileged documents
Pre-Trial Preparation
  • Analyzing client documents, ESI and testimony for relevance to claims and defenses, use in expert reports and exhibit lists, and for witness preparation
  • Drafting pretrial evidentiary motions and memoranda in support
Steve has also coordinated the development of secure websites that serve as electronic clearinghouses for the collection and distribution of attorney work product and other materials relevant to specific litigation claims and issues.