Lee Weatherly and Kristen Thompson showed how the use of discovery of fact and expert witnesses can produce effective results. After a limited number of targeted depositions of certain fact and expert witnesses, Lee and Kristen drafted a Motion for Summary Judgment in Federal Court arguing that Plaintiffs could not prove they were entitled to punitive damages in a wrongful death case involving a bicyclist. After the motion was filed, Plaintiffs agreed to a settlement amount that was 10% of their final demand before suit was filed. This effective discovery and motions practice allowed the case to resolve satisfactorily while limiting defense costs and preventing possible excess exposure to the individual clients.