Celesq® Programs

Discovery Strategies in Wage & Hour Class and Collective Actions Before and After Certification of Putative Class

Program Number
Program Date
CLE Credits

Wage & hour class and collective actions are complex and discovery intensive. Discovery requests are often burdensome, seeking information concerning a broad swath of workers. This causes the discovery process to sometimes linger for years and creates a significant expense for employers. Employments litigators are increasingly raising proportionality arguments as a basis for objecting to opposing counsel’s discovery requests. Drafting discovery requests that are likely to withstand burden and proportionality challenges and objections to broad discovery requests is critical for litigators representing in employers in wage & hour class and collective actions. 

This CLE course will guide employment litigators to pursue or object to discovery requests in wage and hour class and collective actions and for dealing with discovery disputes that arise throughout the litigation. The panel will discuss how courts interpret and apply the proportionality doctrine to rein in broad discovery requests in wage and hour cases. 

Learning Objectives: 

  • Common discovery challenges counsel face when litigating wage and hour collective and class actions
  • Effective strategies in wage and hour collective and class actions for obtaining essential information with the least expense
  • Managing the scope of discoverable evidence before and after certification of the putative class
  • Considerations for drafting discovery requests in wage & hour class and collective actions to align with the proportionality standard

Available in States

  • California
  • Colorado
  • Florida
  • Georgia
  • New Jersey
  • New York
  • Texas Self Study

Program Categories

  • Complex Litigation
  • Employee Benefits & Compensation
  • Employment & Labor Law
  • Federal Courts
  • Florida Eligible
  • Litigation & Litigation Skills
  • Litigation and Appeals


  • Areas of Professional Practice : 1 Credit