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Li. v. Merck Addresses: Trigger; Spoliation Discovery; and, Document Unitization

In Li v. Merck & Co., Inc., 2025 WL 429013 (N.D. Cal. Feb. 7, 2025), the court addressed a number of discovery disputes in a lawsuit by a terminated employee against her former employer....more

Another Approach to Drafting and Discovery of Litigation Hold Notices

By definition, a litigation hold notice is a communication from an attorney to a client regarding the duty to preserve potentially responsive information. In Homeland Ins. Co. of Del. v. Independent Health Ass’n., Inc., 2025...more

Fabricated Text Messages – – Some Lessons Are Never Learned

In Ex-Prosecutor Disbarred For Fabricating Harassing Texts – Law360 (Jan. 7, 2025), Thy Vo reported on a fabrication of evidence case. The decision, State of Colorado vs. Yujin Choi, No 24PDJ019, is not yet posted on Recent...more

Google Avoids Discovery on Discovery Based on Insufficient Foundation for Request

In Taylor v. Google LLC, 2024 WL 4947270 (N.D. Cal. Dec. 3, 2024), the court held that “plaintiffs have not shown a specific deficiency in Google’s document production or a factual basis to believe that Mr. Boyer’s (or anyone...more

What “Expenses” Can a Non-Party Recover for Complying with a Discovery Subpoena?

In OL Private Counsel, LLC v. Olson, 2024 WL 4839277 (D. Utah Nov. 20, 2024), the court addressed recovery of expenses by non-parties for responding to a subpoena....more

Service of a “Preservation Notice” in the Forum District Does Not Confer Long-Arm Jurisdiction Over the Out-of-State Sender

Plastics Industry Assoc. v. Bonta, 2024 WL 4699927 (D.D.C. Nov. 6, 2024), held in part that the defendant’s act of serving a “preservation demand” on the plaintiff in the forum district did not confer long-arm jurisdiction...more

Is Marking Documents as “Work Product” an Admission that the Duty to Preserve is Triggered?

In Stuart v. County of Riverside, 2024 WL 3086634, at *3 (C.D. Cal. Jun. 14, 2024), the District Court found a relationship between work product designations and triggering of the common-law duty to preserve....more

Self-Collection, Discovery About Discovery, and Curative Sanctions

EEOC v. Formel D USA, Inc., 2024 WL 4172527 (E.D. Mich. Sept. 12, 2024), addressed several interesting issues. Among them were: general principles of discovery; the role of counsel in self-collection; discovery on discovery;...more

Takeaways From Felder v. MGM National Harbor

​​​​​​​Felder v. MGM National Harbor, LLC, 2024 WL 3690779(D. Md. Aug. 7, 2024)(Simms, J.), addresses several important issues. First, in Felder, the Court ordered the parties to conduct a “meet and confer” session.  That,...more

A Protective Order Has Teeth – Counsel Disqualified After Court Finds Violations

In US Dominion, Inc. v. Byrne, 2024 WL 3792654 (D.D.C. Aug. 13, 2024), violations of protective orders led to disqualification of counsel. The court began its decision by stating:  “This case arises out of the 2020 U.S....more

“Attachments to Attorney-Client Communications May Be Withheld as Privileged, Without an Independent Basis for Privilege,” But….

In Linet Americas, Inc. v. Hill-Rom Holdings, Inc., 2024 WL 3425795 (N.D. Ill. Jul. 15, 2024), the court held that “attachments to attorney client communications may be withheld as privileged without an independent basis for...more

Discovery About Discovery – When Was Duty to Preserve Triggered?

In Linet Americas, Inc. v. Hill-Rom Holdings, Inc., 2024 WL 3425795 (N.D. Ill. Jul. 15, 2024), the court “allowed [defendants] Hillrom to take limited discovery about when [plaintiff] Linet’s duty to preserve may have...more

Geofence Search Warrant Held Valid

County police officers were investigating a theft of farm equipment. They applied for a “geofence warrant” to be served on Google: “A geofence warrant authorizes the seizure of location data collected from smartphones of...more

StubHub: Modification of ESI Protocol and Denial of Sanctions – Performance Was Impossible

In In re StubHub Refund Litigation, 2924 WL 2305604 (N.D. Ca. May 20, 2024), the court addressed important issues such as modification of an ESI Order and sanctions in the context of “modern attachments” a/k/a “pointers,”...more

Bad Things Can Happen When Company Officers Use Their Private Email Accounts for Work

It is generally unwise to use private email accounts for company business.  Clark v. Council of Unit Owners of the 100 Harborview Drive Condominium Association, 2024 WL 2155021 (D. Md. May 13, 2024)(Quereshi, J.), provides a...more

An Epilog: 4 Things You Never Wanted to Hear + 8 Lessons & a Dispute Over Revealing Recipients of Litigation Hold Notices, All in...

I have posted five blogs – – with links below – – on In Re: Social Media Adolescent Addiction/Personal Injury Products Liability Litigation, 2024 WL 1786293 (N.D. Cal. Feb. 20, 2024), subsequent opinion, 2024 WL 1808607 (N.D....more

4 Things You Never Wanted to Hear + 8 Lessons & a Dispute Over Revealing Recipients of Litigation Hold Notices, All in One Case

In one of the opening paragraphs of In Re: Social Media Adolescent Addiction/Personal Injury Products Liability Litigation, 2024 WL 1786293, at *1 (N.D. Cal. Feb. 20, 2024), the court wrote: At the hearing, the Court...more

There’s No Right or Wrong Answer – But There Are Mistakes

In Rayome v. ABT Electronics, 2024 WL 1435098 (N.D. Ill. Apr. 3, 2024), the court wrote that “it would be in the parties’ interest to reach a negotiated result. It should not be forgotten that a party could be ‘right,’ but...more

One Form of a Custodial Data Map

I am an advocate of data mapping. I also usually attempt to discuss key custodians with opposing counsel. However, in cases with a large number of custodians, I often find that it is difficult to keep track of them,...more

Sometimes Discovery Disputes Do Not Bring Out the Best in Us.

That is what makes the recent decision in M1 Holdings, Inc. v. Members 1st Fed. Credit Union, 2024 WL 182220 (N.D. Ill. Jan. 17, 2024), interesting.  Both of the disputing litigants were ordered to state under oath that they...more

Ninth Circuit – – Don’t Destroy Relevant Texts

Dismissal of plaintiff’s claims under Fed.R.Civ.P. 37(e)(2) was affirmed in Jones v. Riot Hosp. Grp. LLC, __ F. 4th__, 2024 WL 927669 (9th Cir. Mar. 5, 2024). The case is a textbook example of a plaintiff tanking her own case...more

Rusty Texts: Sending Privileged Information to Clients

In ‘Rust’ Armorer’s Phone Snafu Shows Risks Of Texting Clients – Law360 (Feb. 13, 2024), Phillip Bantz wrote: “A legal dust-up over compromised text messages between a movie prop weapons expert and her lawyer in the ‘Rust’...more

Defendant Who Participated in Text Message Exchange Was Not Prejudiced by Disclosure on the Eve of Trial

In Pointer v. State, 2024 WL 70556(Apl. Ct. Md. Jan. 5, 2024)(unreported).   the Appellate Court of Maryland held that disclosure of text messages the day before a criminal trial did not prejudice the defendant.  One...more

“ESI Protocol” v. “Discovery Plan”

“ESI Protocols” are discussed in judicial opinions, articles, webinars, and blogs.  They are flexible and useful; however, they may not meet all of the requirements of Fed.R.Civ.P. 26(f).  After a Rule 26(f) conference, that...more

“Self Help” Discovery in Someone Else’s Dropbox is Held to be Sanctionable

“A trial-level judge in New York has sanctioned [attorneys’ name deleted] for ‘rummaging’ through the Dropbox of its litigation opponent after a third-party vendor accidentally revealed the link in discovery.” D. Cassens...more

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