Mastering Discovery: The Nuts and Bolts (FL) (Recorded Package)

Audio program! (check our CLE Programs page for live versions)

Discovery and e-Discovery are the essential components to building your case – for trial or settlement.

It’s complicated and it’s not complicated.  It’s full of rules and timelines and a lot of moving parts. The tasks and options are enumerable and when it comes to e-Discovery especially, the penalties are severe for getting it wrong.

And having good strategies, skills and ideas is key to doing a good job on discovery.

Attend this course to make sure you get it right – your tasks, your deadlines, your preservation letters, your correspondence, your required conferences and cooperation, and the myriad of things you need to think about and handle when engaging in one of the most important parts of litigation.

And attend this course to learn strategies and receive advice from attorneys on both sides of the aisle who have been doing this a very long time.

Topics you’ll learn about include a basic overview and the things you need to consider at the beginning of your case when you are laying out your discovery plan, as well as new rules in Florida.

You’ll also learn about the Federal Rules of Civil Procedure, sanctions for failure to comply and any recent case law updates, especially related to e-Discovery.

No discovery program would be complete without a discussion about subpoenas and affidavits, as well as motions.

You’ll also get a thorough understanding of e-Discovery, budgets, how to cut costs (if you need to), strategies, FRE 502, authentication, preservation letters, and programs.

Lastly, you’ll hear about one of the most asked about issues – how do you deal with difficult counsel or pro-se litigants.

While depositions will be discussed, we did not cover Depositions in depth in this program, as we recently held an in-depth Deposition Training program. You can order the recording for that program here.



This program was recorded live on March 5 & 7, 2024. The recorded package, available in audio or video format and including seminar materials, will be available approximately two to three weeks after the live program ends.* To order the recorded package, click the link to the right that says “I want a download or DVD/CD.”

* The Video recording is a video of the webinar (including sound of course). The Audio recording is a separate audio only recorded package, for those who wish to listen to it without visuals (such as in the car). You can also purchase both recorded packages at a discount. Note: All downloads must be downloaded to a computer first, before transferring them to another device.


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To order a signed paperback directly from us at a discounted price, including free shipping, click here.

The book is also conveniently available on Amazon in both Kindle and paperback formats.  You can also order her DVDs – for attorneys or in a corporate setting – here.

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Don’t miss this opportunity to improve your presentation skills and make your voice heard!

What You Will Learn


Part 1: Tuesday, March 5, 2024
1:00 p.m. – 4:45 p.m. EST

Program Faculty: Edward Blumberg, Robert “Beau” Blumberg, Cosme Caballero, Stephanie Casey, Veronica Gordon, Jessica Kramer, Douglas McCarron, Laura Noyes, Sheila Oretsky, Melissa Softness and Ligianette “Gigi” Cordova.

1:00 p.m. – 2:00 p.m.
 Overview and Considerations
Edward Blumberg and Sheila Oretsky

  • Deciding What Matters to Your Case
  • Determining Your Goals – What Type of Discovery Do You Want and When?
  • Creating a Good Record
  • Strategy Considerations for Trial
  • Strategy Considerations for Settlement

2:05 p.m. – 2:55 p.m.
Florida State Procedural Issues
Cosme Caballero

  • New FL Discovery Rules
  • Potential Amendments/Changes Coming Soon
  • Timelines
  • Overlooked Deadlines
  • Meet and Confer Requirements
  • Common Mistakes

2:55 p.m. – 3:10 p.m.

3:10 p.m. – 4:00 p.m.
Federal Rules of Civil Procedure
Veronica Gordon 

  • 2015 Amendments to the Rules of Civil Procedure
  • Scope of Discovery / Proportionality
  • Timelines
  • Overlooked Deadlines
  • Meet and Confer Requirements
  • Failure to Preserve / Sanctions and How Courts Have Interpreted Them (and How They Differ from State Rules)
  • Common Mistakes
  • Critical Differences Between State and Federal Procedural Issues/Rules

4:00 p.m. – 4:45 p.m.
e-Discovery State and Federal
Robert “Beau” Blumberg

  • Overview and Considerations
  • Sources and Preservation
  • Considerations When Preparing and Agreeing to an ESI Protocol
  • Cost Saving Measures
  • Use of Technology to Assist in Review and Production of Documents
  • Authentication
  • Federal Rule of Evidence 502
  • Other Key Rules and Timelines
  • Strategies
  • Mistakes Not to Make

Part 2: Thursday, March 7, 2024
1:00 p.m. – 4:45 p.m. EST

1:00 p.m. – 2:15 p.m.
Drafting Effective and Useful Discovery
Laura Noyes and Melissa Softness

  • Requests for Production
  • Interrogatories
  • Requests for Admissions

2:15p.m. – 2:20 p.m.

2:20 p.m. – 2:35 p.m.
Ai as a Discovery Tool
Jessica Kramer

  • AI and eDiscovery
  • TAR and GenAI
  • Courts’ views on use of AI for discovery
  • Challenges with AI

2:35 p.m. – 3:05 p.m.
Subpoenas and Affidavits
Jessica Kramer

  • Use of subpoenas
  • Serving subpoenas
  • Objecting to subpoenas
  • Use of affidavits
  • Requirements of an affidavit

3:05 p.m. – 3:20 p.m.

3:20 p.m. – 4:25 p.m.
Stephanie Casey and Ligiannette “Gigi” Cordova

  • Motions to Compel
  • Motions for Protective Orders
  • Motions for Sanctions

4:25 p.m. – 4:45 p.m.
Dealing with Difficult Counsel
Douglas McCarron

  • Meet and Confer Requirements


“Beau Blumberg was well-spoken and covered a lot of material. Veronica Gordon was very good and well-spoken.” – Tracy Romera, Esq.

“Excellent program.” – Eli Kaplan

“Very insightful and informative.”

“Very helpful and informative content.”

“Sheila Oretsky and Beau Blumberg were both easy to listen to.”

“I enjoyed the speakers today, especially Veronica Gordon.”


While our discovery program is new to Florida, your speakers are not.  Below are testimonials from prior litigation programs at which all of your speakers have taught:

“I really enjoyed the step-by-step analysis from case inception to appeals. I thought all topics were relevant.” ¬– Lauren M. Allen, Esq.

“I took it last year and really enjoyed it. Great program for lawyers making transition from criminal to civil. It gives participants a great overview of civil. I liked the perspective of the judges being contrasted in real time with practitioners.” – MaryAnn Braun, Esq.

“Great first day! Very clear and concise material.” – Hillary Mesa, Esq.

“The speakers were great! I’ve been practicing for over 20 years and they were still able to keep me engaged throughout, great reminders that can be easily forgotten.” – Lisa Ann Gorshe, Esq.

“Very knowledgeable regarding the subjects and had good information.” – Fernando L. Roig, Esq.

“It’s not merely about getting in the required CLE hours. The content of the seminar I attended impressed me and sold me on your programs. It’s very easy to get the hours. Getting something of substance that is beneficial is different. I’m proud to say that this is what separates you from the competition.” – Jerry Szymanski, Esq.

“I really enjoyed the step-by-step analysis from case inception to appeals. I thought all topics were relevant.” ¬– Lauren M. Allen, Esq.

“I took it last year and really enjoyed it. Great program for lawyers making transition from criminal to civil. It gives participants a great overview of civil. I liked the perspective of the judges being contrasted in real time with practitioners.” – MaryAnn Braun, Esq.

“The program was incredibly educational. Wish these were available for third year law students.” – Juliette Orozco, Esq.

“This was a very informative program with great real-life advice.” – Elika Stimpson, Esq.

“I thought it was very well done, really enjoyed the topics and information given, and the diversity of the speakers and their backgrounds.” – Katherine van Dijk, Esq.

“Very positive and informative. Good content and speakers. The materials were good and complemented the speakers.” – Dorothy G. Negrin, Esq.

“As a young lawyer, the speakers touched on subjects I would encounter and areas I am not so comfortable with. Their suggestions on how to handle certain situations were great.” – Stacey Marquez, Esq.

“Judge was great. Learned a lot about how FL will permit open ended questioning to root out prejudice. The insight from the judge and the young but experienced trial lawyers was very helpful.” Vincent Indeglia, Esq.

“The speakers were extremely knowledgeable; When there was more of a panel discussion as opposed to a single speaker talking for extended periods of time made for the best learning experience. Excellent seminar, highly recommend to anybody that wants to learn about jury selection.” – Matthew Baron, Esq.

“Great program, wouldn’t change anything.” – Glenn Danas, Esq.

“The program was very good. Very thorough.” – Thomas Anthony Trapani, Esq.

“Fantastic program. Impressed with preparation.” – Francis Carroll, Esq.


“It’s not merely about getting in the required CLE hours. The content of the seminar I attended impressed me and sold me on your programs. It’s very easy to get the hours. Getting something of substance that is beneficial is different. I’m proud to say that this is what separates you from the competition.” – Jerry Szymanski, Esq.

“I have utilized all of the service providers that I noted in the survey and truly felt I received great service from each.  My favorite continuing legal education seminar provider, Pincus Professional Education is particularly noteworthy though.  I have attended about five Pincus seminars.  Each was phenomenally packed with useful content and had presenters/speakers of the highest skill level.  I would unhesitatingly recommend Pincus to other lawyers and am already planning my next couple of seminars with this CLE provider.”  – Quote from The Recorder’s survey.


Edward R. Blumberg, Esq.
Partner and Co-Founder
Deutsch Blumberg & Caballero P.A.

Edward R. Blumberg is a graduate of the University of Georgia and earned his law degree from the College of William and Mary. He has practiced continuously in Florida since 1975. He has served as President of the Florida Bar, as a member of the Board of Governors of the Florida Bar and as a member of the House of Delegates of the American Bar Association. He has chaired and served on countless professional committees and groups and provides continuing legal education lectures to lawyers. Since 1983 he has been continuously certified and re-certified in civil trial law by The Florida Bar and The National Board of Trial Advocacy.

Robert (Beau) Blumberg, Esq.
Deutsch Blumberg & Caballero P.A.

Robert (Beau) Blumberg was born and raised in Miami, Florida. He is a Partner with Deutsch, Blumberg & Caballero P.A., where he practices personal injury, medical malpractice, and product liability law. Mr. Blumberg is admitted to practice in Florida and before the United States District Court for the Southern and Middle Districts of Florida.

Cosme Caballero, Esq.
Deutsch Blumberg & Caballero P.A.

Mr. Caballero is a graduate of the University of Miami School of Law where he served as Articles & Comments Editor of the University of Miami Law Review, where he published an article titled Curbing Corporate Abuse from Jurisprudential Off-Sites: Problematic Paradigms in United States v. Textron Inc. Following graduation, Mr. Caballero was admitted to practice law in Florida.  He was also admitted to practice in the United States District Court for the Southern District of Florida and the Eleventh Circuit Court of Appeals. He is a member of the Dade County Bar Association and is a Florida Bar  Grievance Committee Member for the 11th Judicial Circuit.

Stephanie A. Casey, Esq.
Colson Hicks Eidson

Stephanie A. Casey is a committed litigator who has dedicated her career to achieving justice for her clients in a commercial, class action, False Claims Act, and personal injury cases. Stephanie represents clients in state and federal trial and appellate courts in Florida, New York and Washington, DC. As a native of Brazil, she speaks Portuguese fluently.

Stephanie joined Colson Hicks Eidson after completing a judicial clerkship with United States District Judge Marcia G. Cooke. Prior to her clerkship, Stephanie worked for several years at a large corporate law firm in Washington DC, where she represented the U.S. and international clients in a wide range of antitrust, securities, and commercial litigations as well as white collar defense matters.

Ligianette Cordova, Esq.

  Ligianette “Gigi” Cordova focuses her practice on casualty litigation.  She represents clients in negligence claims involving personal injury.

Prior to entering private practice, Gigi served as a law clerk for the Honorable Migna Sanchez-Llorens of the Eleventh Judicial Circuit Court and also as an assistant general counsel for the Office of the General Counsel for the Eleventh Circuit.

Veronica Gordon, Esq.
Senior Associate
White & Case, LLP

Veronica is an associate in the Firm’s Commercial Litigation Group whose practice focuses on complex litigation and appeals. She has served clients in commercial, constitutional, and bankruptcy disputes, and in statutory interpretation and white-collar matters, among others.

Before joining the Firm, Veronica served as a law clerk to the Honorable Robert N. Scola, Jr. of the United States District Court for the Southern District of Florida and as a law clerk and staff attorney to the Honorable Adalberto Jordan of the United States Court of Appeals for the Eleventh Circuit. As a former federal law clerk and a fluent Spanish speaker, Veronica is uniquely suited to assist clients across different industries in a variety of cases.

Jessica S. Kramer, Esq.

Holland & Knight LLP

Jessica Kramer is a litigation attorney in Holland & Knight’s Tampa office. Ms. Kramer has extensive experience assisting individuals and businesses with contract disputes, class action lawsuits, appeals, and other complex litigation.

Since joining Holland & Knight, Ms. Kramer has gained significant experience representing companies in data privacy litigation, and has defended dozens of companies in high-stakes lawsuits arising from data breaches, a company’s use of technology on company websites, and other privacy issues. Ms. Kramer also advises clients on data privacy-related issues, including responses to data breaches and updates to customer-facing privacy policies and other terms.  Ms. Kramer has experience litigating cases in arbitration proceedings as well as jury trials and bench trials throughout the State of Florida.

Prior to joining Holland & Knight, Ms. Kramer served as a federal law clerk for two years to the Honorable James S. Moody Jr. of the U.S. District Court for the Middle District of Florida. 

Douglas J. McCarron, Esq.
The Haggard Law Firm

Douglas J. McCarron is an accomplished trial lawyer with significant experience handling a wide variety of cases including negligent security, pool drowning, dram shop, and construction and auto accidents. 

Doug served as an Assistant State Attorney in Miami-Dade County for four years. While there, Doug was a member of the Career Criminal Unit where he distinguished himself in over 50 trials prosecuting violent crime. Upon leaving the State Attorney’s Office in 2000, Doug began to focus on representing victims of serious and catastrophic injury. 

Doug joined The Haggard Law Firm in 2006 and became a partner in 2007. Since joining the firm, he has recovered over 150 million in verdicts and settlements for his clients. In Garcia v. Arbors Apartments, Doug successfully obtained a million jury verdict on behalf of the Garcia family. This negligent security/wrongful death case found the owners and managers of the apartment complex guilty of failing to provide adequate security on their property. Doug has been able to recover similar results in cases throughout Florida. Doug served as President of the Miami-Dade Trial Lawyers Association in 2013 and was recently appointed by the Florida Supreme Court to serve on the Civil Standard Jury Instructions Committee. Doug is also a member of the American Board of Trial Advocates and the Florida Justice Association. 

Outside the office, Doug enjoys spending time with his wife Becky and their three boys, Jack, Finn and William Andrew (Drew). Doug and Becky are extremely active in a number of local charities and truly believe in giving back to the community. Doug was born in Atlantic City, New Jersey but moved to Miami as a young boy. He graduated from Miami Archbishop Curley Notre Dame High School. Doug received his Bachelors of Science in 1993 and his Juris Doctorate in 1995, both with Honors, from Florida State University.

Laura E. Noyes, Esq.
Kass Shuler, PA

 Laura Noyes is a Shareholder in the Tampa office of Kass Shuler where she focuses her practice on real estate litigation with an emphasis on representation of lenders, loan servicers, investors and debt collectors in the consumer finance industry. Ms. Noyes manages a portfolio of highly-litigated state court cases focused in the areas of consumer banking and real estate litigation, where she: collaborates with in clients to develop and implement litigation, settlement and trial strategies to minimize risk and future exposure; drafts pleadings, discovery, memos, motions, settlement agreements, and other legal documents necessary to achieve favorable resolutions; and conducts legal research to obtain answers to complex issues of law or facts.

Ms. Noyes started with the Firm in 2010. Prior to joining, Ms. Noyes worked for a Tampa defense firm in the areas of consumer litigation and foreclosure defense. In 2008, Ms. Noyes earned her Juris Doctor from the Florida State University College of Law. While attending law school, Ms. Noyes interned for the Honorable Lewis M. Killian Jr at the Northern District of Florida Bankruptcy Court. 

A. Sheila Oretsky, Esq.
Greenberg Traurig, LLP

Sheila Oretsky is ranked by Chambers USA for her work in commercial litigation and is a Martindale Hubbell AV rated litigator and trial attorney. Prior to joining GT, Sheila served as the co-chair of the Class Action Committee at a national law firm. Sheila represents domestic and international clients in complex commercial litigation matters across a range of industries and she is often called upon to litigate high-profile matters and issues of first impression all the way through an appeal. She regularly advises on highly contentious complex matters related to defamation, fiduciary claims, director and officer liability, non-competes and trade secrets, partnership disputes, business divorces, breach of contract, civil RICO, EB-5 related litigation, professional malpractice, commercial landlord/tenant disputes, insurance, andbusiness torts such as fraud. She is also experienced in class action defense of a variety of claims and often serves as an outside general counsel for her clients advising family offices and private equity firms on litigation and other risks. Her experience includes representations related to disputes stemming from international mergers and acquisitions and real estate disputes with publicly traded retail tenants and multibillion-dollar landlords. Sheila also has significant experience in the payments and credit card processing industry. Sheila is licensed in Florida and New York and litigates matters in federal and state courts across the country as well as in arbitrations including international arbitrations before the ICC. Her practice also regularly includes serving as a testifying attorneys’ fees expert and a judicially appointed special master.

Melissa I. Softness


Melissa Softness focuses her practice in the areas of product, employment and casualty litigation.  She represents clients in the manufacturing, distribution, retail, automotive, boating, marine and personal watercraft industries throughout Florida against negligence and product defect claims. Melissa also represents employers against claims of employment discrimination and retaliation such as religion, national origin, race, gender, age, and political patronage, asserted under Title VII of the Civil Rights Act of 1964; Chapter 760, Florida Statutes; Section 1983 of the Civil Rights Act of 1871; the American Disabilities Act (ADA); and the Age Discrimination in Employment Act (ADEA.)

While working at the Office of the State Attorney for Miami-Dade County, Melissa gained extensive trial experience, trying 18 jury trials and more than 50 bench trials. In addition, she conducted several highly contested evidentiary and Daubert hearings and successfully defended a First Amendment Appeal.

Before joining RumbergerKirk, she worked in civil practice gaining further trial experience in both state and federal courts.

Drawing on her trial experience, Melissa teaches trial skills to law students by serving as a faculty member at the Kessler-Eidson Program for Trial Techniques at Emory Law. This week-long, required course for students includes a series of workshops that culminates with a simulated jury trial. The program integrates second-year students’ knowledge of substantive evidence law with practical skills in a “learning-by-doing” format, all under the watchful eye of renowned trial lawyers, judges, and trial skills teachers who travel in from all over the country to teach Emory’s students.



Three Recorded Package options to choose from:

Video (with sound)* Recording & Materials Package – CD or Download:  $429

Audio Only* Recording & Materials Package – CD or Download:  $429

Order both the Video* and Audio Only* Packages for only $50 more – CD or Download:  $479


For CDs, please add $8.50 shipping and, in CA, sales tax.

This program will be recorded live on March 5 & 7, 2024


*The Video recording is a video of the webinar (with sound). The Audio recording is audio only, for those who wish to listen to it without visuals (such as in the car).

Note: All downloads must be downloaded to a computer first, before transferring them to another device. 

(Recorded packages are available approximately two to three weeks after the seminar is held.)

CLE Credit

FL General: This program is approved for 7.5 units of  General and 0.5 units of Technology CLE Credits in FL through 09/30/25.

CA General:  This program is approved for 6.75 units of general CLE in California.

NY General: This course is eligible for approval, under New York’s CLE Approved Jurisdiction policy, for 6.75 CLE units. Pincus Professional Education is a CA Accredited Provider, which is a NY approved jurisdiction. See Section 6 of the New York State CLE Board Regulations and Guidelines for further information.

This program is approved for CLE in the states listed above.  Upon request, Pincus Pro Ed will provide any information an attorney needs to support their application for CLE approval in other states other than what is listed above. Many attorneys ask for this and are approved in other states.

$429.00$479.00 each

Recorded on March 5 & 7, 2024.