Discovery Plan
(Title VII Discrimination Cases) (Pro-Employee)


Summary

This template is a discovery plan for plaintiff-side attorneys to use in Title VII cases involving discrimination, harassment, and retaliation. Plaintiff-side attorneys can use this template to enumerate the components of each claim that a plaintiff must establish at trial, responses to potential defenses by employers, the type of evidence that plaintiffs can proffer, and how to obtain such evidence. This template assumes that you know what evidence your client has and what he or she will testify to, but have not yet served any discovery requests or taken depositions. You should replace the information in brackets with information specific to your particular case. For more information on Title VII claims in general, see Title VII Compliance Issues, Disparate Treatment: Key Considerations, Disparate Impact Claims: Key Considerations, Harassment Claim Prevention and Defense, and Retaliation Claim Elements: Key Considerations. For tracking of recent case law related to plaintiff-side ...