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Document Production — Look Before You Leap

In eDiscovery, look before you leap! You have filed a lawsuit and you are set for a “meet & greet” conference with opposing counsel(s) to review and agree on discovery. What should you expect from opposing counsel and their...more

Federal Rule 34 Primer — A shepherd’s guide to “herding cats”

Herding Warrior Cats - Federal Rules were last updated in 2016 and the changes were thought to be significant. Welcomed by some and scorned by others, those changes are still being evaluated and applied by judges across...more

E-Discovery Production — Snow storms are avoidable

Who is to blame for a “document dump” – a “snow storm” – an obfuscation of information? Sometimes its intentional and sometimes it is not. Everyone – both plaintiff and defendant; both teams of lawyers. Requesters are...more

BYOD – Another reasonable basis for discovery about discovery

I still remember typewriters. Heck, I still remember carbon paper, mimeographs and bag phones. Would a company, “back in the day”, have ever asked an employee, “hey, we need you to bring your own typewriter, desk,...more

E-Discovery — Setting standards, not cover

The Sedona Conference has a slogan: “Moving the law forward in a reasoned and just way”. That slogan is exactly the way I have described this impressive organization and what do....more

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