UTBMS Code L310 — Written Discovery
Drafting, reviewing, and responding to interrogatories, requests for production, requests for admission, and other written discovery requests. This covers both propounding and responding to written discovery.
schedule When This Code Is Used
When the legal team is drafting interrogatories or document requests to the opposing party, or when preparing responses and objections to the other side's written discovery requests.
warning Common Billing Violations
Billing partner hours to draft boilerplate interrogatories or requests for production that are largely template-driven
Charging for excessive rounds of review on standard discovery responses that experienced associates should handle
Over-billing for discovery objections that are largely standardized across litigation practice
Block billing the drafting of multiple discovery requests as a single large time entry to obscure actual effort per request
timer Typical Hours
Drafting standard interrogatories: 5-15 hours. Responding to interrogatories: 10-30 hours. Document request sets: 5-20 hours per set.
flag Red Flags to Watch For
More than 40 hours billed for a standard set of 25 interrogatories in a non-complex case
Partner billing significant hours on boilerplate discovery responses
L310 hours that are disproportionate to the number of discovery requests actually served
Repeated rounds of revisions to standard objections that should be settled in the firm's template library
check_circle Best Practices for Review
Require firms to disclose when discovery templates are used as starting points
Establish that standard discovery objections are associate-level work with minimal partner review
Set per-request-set budgets based on matter complexity
Compare total L310 hours against the actual number and complexity of discovery requests exchanged
link Related Codes
analytics Key Statistics
Discovery costs represent 30-50% of total litigation spend in complex commercial cases
Source: RAND Institute for Civil Justice, 2024
Written discovery requests have increased 35% in volume over the past decade due to expanding ESI obligations
Source: Thomson Reuters Litigation Trends Survey, 2024
Frequently Asked Questions
What does UTBMS code L310 cover for written discovery? expand_more
UTBMS code L310 covers Written Discovery activities including drafting and responding to interrogatories, requests for production, and requests for admission. It is one of the most commonly billed litigation codes, and billing reviewers should watch for excessive hours on routine discovery responses.
How do you spot overbilling on written discovery under L310? expand_more
Watch for senior attorneys drafting boilerplate discovery requests, excessive hours on standard interrogatory responses, duplicative objections drafted individually rather than using templates, and attorneys billing for discovery tasks that paralegals should handle such as compiling response documents.
What is a reasonable hour range for written discovery under L310? expand_more
Simple matters typically require 10-30 hours for L310 work. Moderate cases with multiple discovery sets may reach 40-100 hours. Complex multi-party litigation can exceed 150 hours. Hours should correlate with the number and complexity of discovery requests served and received.