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Chancery Declines to Compel Discovery Concerning Alleged Personal Misconduct in the Context of a Broken Deal Case

Albertson Cos. Inc. v. The Kroger Co., C.A. No. 2024-1276-LWW (Del. Ch. Sept. 12, 2025) - The discovery process is meant to shed light on the issues in a case and provide information relevant and necessary to arguing the...more

Company’s Shifting Positions on Data Server at Center of Books and Records Action Lead to Bad Faith Sanctions

Magna-D Glob. Healthcare No. 1 Private Equity Fund v. CoImmune, Inc., C.A. No. 2024-0456-SEM (Del. Ch. June 3, 2025) (report granting fee-shifting) - Magna-D Global Healthcare No. 1 Private Equity Fund v. Coimmune, Inc.,...more

Chancery Grants Sanctions for Texts Deleted after Litigation Hold Notice

Infab Holdco, Inc. v. Cusick, 2022-0050-KSJM (Del. Ch. Jun. 9, 2025). In Delaware, the duty to preserve documents includes not just issuing a litigation hold but also complying with the hold’s requirements, including by...more

Court of Chancery Reasons that Using Generative Artificial Intelligence Requires Proper Oversight and Confirmation

An v. Archblock, Inc., C.A. No. 2024-0102-LWW (Del. Ch. Apr. 4, 2025) - The Delaware Court of Chancery found that the authority cited in a pro se litigant’s motion to compel discovery was incorrect and apparently prepared...more

Rare Discovery and Bankruptcy Opinion from the Third Circuit

The Third Circuit recently clarified that the unsealing of confidential documents subject to protective order in bankruptcy cases is governed by § 107 of the Bankruptcy Code, rather than the common law....more

Mentorship and the Evolving Practice of Law

The practice of law requires the synthesis of law, regulation, and judicial holdings into cohesive legal advice. The best way to develop skill is under the guidance of a more experienced attorney, as reflected by the American...more

Court of Chancery Finds Class Counsel’s Litigation Funding Agreement is Discoverable

Burkhart v. Genworth Fin., Inc., C.A. No. 2018-0691-NAC (Del. Ch. Aug. 21, 2024). The rise in litigation funding brings a predictable follow-on question: Are litigation funding agreements protected as work product, or...more

Failure to Maintain Legal Hold Leads to Spoliation, Sanctions, and Fee Shifting in Delaware Superior Court CCLD

Huntsman Int'l, LLC v. Benelux, C.A. No. N17C-11-242 MAA CCLD (Del. Super. Ct. Aug. 13, 2024). In the age of big data, discovery can extend beyond traditional documents and communications to myriad tools and databases....more

Chancery Finds Egregious Conduct in Books and Records Action Justifying Fee-Shifting Against Corporation

PVH Polymath Venture Holdings Ltd. v. TAG Fintech Inc., C.A. No. 2023-0502-BWD (Del. Ch. Jan. 26, 2024) - Under the “bad faith” exception to the American Rule, Delaware courts will consider shifting fees when aggressive...more

A.I. Enthusiasm May Outpace Current Application, But Not For Long

The topic of Artificial Intel­ligence dominated both the popular and professional land­scapes for the last year, exemplified by the release and subsequent downloads of the generative A.I. program ChatGPT, resulting in well...more

Generative A.I. Tools in eDiscovery

ChatGPT rolled out to the public in November 2022, and “Generative A.I.” has captured the public's imagination in the 15 months since the popular program and others like it became available....more

Chancery Finds Wholly Generic Objections to Discovery Requests Result in Waiver and Fee-Shifting

Bocock v. Innovate Corp., C.A. No. 2021-0224-PAF (Del. Ch. Dec. 6, 2023) - In this recent letter opinion, Vice Chancellor Fioravanti considered whether the plaintiffs’ failure to provide specific objections to discovery...more

Cybersecurity THREATS, RESPONSE, AND SOLUTIONS

Cyber-attacks become more common with each passing year, and the increased number of attacks means more protected data is vulnerable to data breach. As more and more business has moved online in the twenty-first century,...more

The Importance of Privilege Logs to Delaware Litigation

On February 9, at the Rubenstein-Walsh CLE on Ethics and Professionalism for the Delaware State Bar Association, a panel of experts, including Vice Chancellor Cook, discussed the importance of these logs, and the care and...more

Spoliation of Email and Texts Leads to Adverse Inferences and Fee Shifting

Gener8 LLC v. Castanon, 2022-0246-LWW (Del. Ch. Sept. 29, 2023) - This dispute concerned a non-compete agreement that the plaintiffs alleged the defendant breached by establishing a competing business. The defendant denied...more

Chancery Orders Discovery Record Be Made Available to Stockholders in the Settlement Class

In re AMC Entertainment Hldgs., Inc. S’holder Litig., 2023-0215-MTZ (Del. Ch. May 20, 2023) - Under Delaware law, class members are entitled to access to the discovery record to assess the terms of a proposed class action...more

Chancery Prioritizes Efficiency in Ruling on Discovery Motions

Brown v. Matterport, Inc., 2021-0595-LWW (Del. Ch. Jun. 5, 2023) - The plaintiff sued alleging that the defendants had used lockup restrictions to improperly prevent him from selling shares....more

Chancery Addresses When Third Parties Are Within the Scope of the Privilege

Police and Fire Ret. Sys. of the City of Detroit v. Musk, C.A. No. 2020-0477-KSJM (Del. Ch. January 31, 2023) - A communication is privileged under Delaware Rule of Evidence 502(b) if it is confidential and "made for the...more

Threading the Labyrinth of Modern Email Collections

At this moment, communication is more instantaneous and readily available than at any other point in recorded history, and "recorded history" grows exponentially with each passing year. Across the globe, we collectively...more

Delaware Court Enters Default Judgment for Extreme Spoliation

Spoliation of evidence can lead to significant litigation sanctions, including adverse inferences, fee-shifting, and—in egregious cases—the entry of a default judgment. In this recent case involving intentional spoliation of...more

Chancery Permits Discovery Under the Hague Evidence Convention

In Re Cote D’Azur Estate, C.A. No. 2017-0290-JTL (Del. Ch. Dec. 12, 2022) - The Hague Evidence Convention provides an alternative method from the Federal Rules of Civil Procedure to compelling production from opposing...more

Superior Court Upholds Highly Confidential Designations in Discovery

Surf’s Up Legacy Partners, LLC v. Virgin Fest, LLC, C.A. No. 19C-11-92 (Del. Super. June 6, 2022) - Delaware courts generally do not permit the redaction of non-responsive material that is otherwise not privileged....more

Chancery Holds That Requests for Admission Are Subject to Discovery Deadlines

NetApp, Inc. v. Cinelli, Inc., C.A. No. 2020-1000-LWW (Del. Ch. June 3, 2022) - This decision clarifies discovery deadlines under the Court of Chancery rules....more

Chancery Applies Privilege Rules in Business Negotiations Context

Twin Willows, LLC v. Pritzkur, C.A. No. 2020-0199-PWG (Del. Ch. Feb. 28, 2022) - This decision involved a Master in Chancery applying well-settled rules on the attorney-client privilege, common interest, and work product...more

Chancery Finds Former Directors Bringing Wrongful Termination Claims Were Not Entitled to all Privileged Communications During...

SerVaas v. Ford Smart Mobility LLC, C.A. No. 2020-0909-LWW (Del. Ch. Nov. 9, 2021) - With limited exceptions, directors normally have “unfettered” access to corporate information. This decision indicates, however, that the...more

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