UTBMS Code L350 — Discovery Motions
Preparation and argument of motions to compel, motions for protective orders, and other discovery-related motions. This covers the contentious side of discovery when parties cannot resolve disputes informally.
schedule When This Code Is Used
When discovery disputes cannot be resolved through meet-and-confer discussions and require court intervention, including motions to compel production, motions for protective orders, and sanctions motions.
warning Common Billing Violations
Filing unnecessary discovery motions to generate billable hours when a phone call with opposing counsel would resolve the issue
Over-billing for meet-and-confer discussions that are required before filing discovery motions
Billing for discovery motions that are denied because they were premature or procedurally deficient
Using L350 to capture general discovery dispute time that does not involve actual motion practice
timer Typical Hours
Standard motion to compel: 10-25 hours. Protective order: 10-20 hours. Complex discovery dispute with briefing: 25-60 hours.
flag Red Flags to Watch For
L350 hours exceeding 5% of total discovery spend, suggesting excessive motion practice
Discovery motions filed without proper meet-and-confer as required by court rules
A pattern of filing discovery motions that are consistently denied by the court
High L350 billing with no corresponding motion filings on the court docket
check_circle Best Practices for Review
Require pre-approval before filing any discovery motion, with a cost-benefit analysis
Establish that meet-and-confer efforts must be exhausted and documented before motion filing
Set per-motion budgets for discovery motions based on the complexity of the dispute
Track the success rate of discovery motions to assess whether they are being filed strategically
link Related Codes
analytics Key Statistics
Discovery disputes account for 10-15% of total discovery costs, with the average motion to compel costing $20,000-$40,000
Source: RAND Institute for Civil Justice, 2024
Courts grant discovery motions to compel in approximately 60-70% of cases, though sanctions are awarded in fewer than 15%
Source: Federal Judicial Center, 2023
Frequently Asked Questions
What does UTBMS code L350 cover for discovery motions? expand_more
UTBMS code L350 covers motions related to discovery disputes, including motions to compel, motions for protective orders, motions regarding discovery sanctions, and other court intervention in the discovery process. It is separate from general pre-trial motions under L250.
When should discovery disputes be coded to L350 vs L250? expand_more
L350 is specifically for discovery-related motions such as motions to compel or protective orders. L250 covers non-dispositive pre-trial motions that are not discovery-specific. Proper coding ensures accurate tracking of discovery dispute costs as a distinct category of litigation spend.
How do you reduce L350 discovery motion costs? expand_more
Require meet-and-confer efforts before authorizing any discovery motion. Set budget limits per motion and require advance approval. Track the success rate of discovery motions to evaluate whether the costs are justified by outcomes. Many disputes resolve through informal negotiation at a fraction of motion costs.