The defense-oriented group has been especially active on e-discovery issues; Lewis Collins, its president, is interviewed by Metropolitan Corporate Counsel and outlines LCJ's agenda on a variety of issues including procedure:

(1) pleadings should be fact pleading, not notice pleading;

(2) the scope of all discovery should be limited to material, proportional information, e.g., information necessary to prove a claim or defense or for impeachment;

(3) discovery should be by initial disclosure followed by focused and limited discovery proportionally tied to claims actually at issue;

(4) early disposition of cases through motions should be a priority;

(5) early identification of the issues to be tried should be required; and

(6) courts should consider staying discovery in appropriate cases until a motion to dismiss is decided.