Advanced Discovery Techniques

This CLE will cover Discovery techniques, including tricks of the trade, as set forth in Rule 26, which states:

RULE 26. General Provisions Governing Discovery

(A) Policy; discovery methods. It is the policy of these rules (1) to preserve the right of

attorneys to prepare cases for trial with that degree of privacy necessary to encourage them to

prepare their cases thoroughly and to investigate not only the favorable but the unfavorable

aspects of such cases and (2) to prevent an attorney from taking undue advantage of an

adversary's industry or efforts.

Parties may obtain discovery by one or more of the following methods: deposition upon

oral examination or written questions; written interrogatories; production of documents,

electronically stored information, or things or permission to enter upon land or other property, for

inspection and other purposes; physical and mental examinations; and requests for admission.

Unless the court orders otherwise, the frequency of use of these methods is not limited.

7 part video, duration of 01:04:10.
Production Date
State Due Date Credit Information

John H. Metz

John H. Metz


  • 1974 - B.A., University of Cincinnati; English major with 75 credit hours of
  • Sciences (including Organic Chemistry; Inorganic Chemistry; Physics, Biology;
  • Bacteriology; Comparative Anatomy; Modem Physics; Acoustics; Oceanography).
    • Staff writer/music reviewer University of Cincinnati News Record
  • 1977 - Juris Doctor: Franklin Pierce Law Center, Concord, New Hampshire;
    • Editorial Board of IDEA [PTC Research Foundation publication dealing with
  • Patents, Trademarks and Copyrights]
    • Associate Editor and Art Editor of Obiter Dictum [legal humor magazine]


  • Supreme Court of Ohio, November 1977
  • Supreme Court of Kentucky, April 1994
  • United States District Court, Southern Ohio, December 1977
  • United Stated District Court, Northern Ohio, July 1980
  • United States District Court, Eastern District of Kentucky,
  • September, 1987
  • United State District Court, Western District of Kentucky, 2008
  • U.S. Sixth Circuit Court of Appeals, February 1978
  • U.S. Fourth Circuit Court of Appeals, 2001
  • United States Supreme Court, July 1982


  • Certified, American Board of Trial Advocacy in Trial Practice [NBTA certification]
  • Association of Trial Lawyers of America [ATLA ] [now American Association for
  • Justice (AAJ)] (member since 1976)
  • Ohio Academy of Trial Lawyers [OATL] (now Ohio Association for Justice) [OAJ]
  • Hamilton County Trial Lawyers Association [Past President 2002 and 2003] *
  • elected by my peers.
  • Ohio State Bar Association
  • Ohio State Bar Association College
  • Cincinnati Bar Association
  • Kentucky Bar Association
  • Past Chairman, Tort & Insurance Committee of Cincinnati Bar Assn.
  • Emeritus member/lecturer, Federal Inns of Court
  • Birth Trauma Litigation Group [Obstetrical Malpractice Group]
  • Traumatic Brain Injury Litigation Group [TBI Group]
  • Attorneys Information Exchange Group, Inc. [Auto industry - negligent design]
  • JEEP Litigation Group [re: JEEP roll-over cases]
  • DES Litigation Group [diethylstilbesterol pregnancy medication]
  • Civil Rights Litigation Group


  • I have tried cases in Cincinnati; Columbus; Cleveland; Dayton, Lebanon, Hamilton,
  • Ashtabula, Painesville, Ohio; Kentucky and West Virginia; (and appeared pro haec
  • vice in New Mexico and Michigan).


  • orally argued twelve (12) times before the Ohio Supreme Court
  • orally argued before the Kentucky Supreme Court
  • orally argued before the Michigan Supreme Court
  • orally argued before the 1st, 2nd, 10th, 11th and 12th District Ohio Courts of Appeal;
  • orally argued before the Federal 6th Circuit numerous times
  • orally argued before the Federal 4th Circuit (Richmond, Virginia)