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Sometimes Discovery Disputes Do Not Bring Out the Best in Us – Part II

It is not auspicious when a court writes: “The court notes that, from time to time, in contentious cases like this one, courts have ordered that the parties record – by video or court reporter – their Local Rule 37.2...more

Another Cinderella Situation – Motion Denied as Untimely?

In Fiskars Finland OY AB v. Woodland Tools Inc., 2024 WL 2504717 (W.D. Wisc. May 24, 2024), plaintiff sued for alleged misappropriation of trade secrets. Defendants counterclaimed....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

ESI Protocol Dispute – “Modern Attachments” and the “Humpty Dumpty Issue”

In Re: Uber Technologies, Inc., Passenger Sexual Assault Litigation, 2024 WL 1772832 (N.D. Cal. Apr. 23, 2024), resolved a dispute over so-called “modern attachments” based on impressive and comprehensive technical...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

What Happens When Parties Fail to Negotiate a Privilege Log in Good Faith?

In Kyle Rayome v. ABT Electronics, 2024 WL 1435098 (N.D. Ill. 2024), the court wrote that it “would prefer this case not go to the dark place where attorneys on one side demand that the attorneys on the other side provide...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

Failure to Show “Intent to Deprive” Leads to Denial of Rule 37(e)(2) Sanctions

A motion for spoliation sanctions under Fed.R.Civ.P. 37(e) was denied in Boshea v. Compass Marketing, Inc., 2024 WL 811468 (D. Md. Feb. 27, 2024). The motion was argued and decided during trial. The suit by a former...more

Authentication of Entire Video When Witness Observed Only Part of the Events Portrayed in the Video

Can a witness authenticate a video if the video contains images that the witness did not see?  In Md. Supreme Court to rule on Baltimore criminal case involving video authentication – Maryland Daily Record...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

Do “Evasive and Incomplete” Discovery Responses Support Draconian FRCP 37(d) Sanctions?

In Ogunsula v. Warrenfeltz, 2024 WL 298984 (D. Md. Jan. 25, 2024), the Court recognized a split of authority and addressed the interplay between Rule 37(a)’s maxim that “evasive and incomplete” discovery responses are deemed...more

And When I Die… What Happens to My Social Media? – – Part II

In a prior blog, And When I Die…. What Happens to My Social Media?, I discussed Maryland’s “Fiduciary Access to Digital Assets Act” (“MFADAA”). The statute permits the “user” of “digital assets” to authorize a designee to...more

“Self-Collection” May Be Reasonable Using Ralph Losey’s Dual-Protection System

“Self-collection” is often viewed as prohibited.  Abraham Maslow said that: “I suppose it is tempting, if the only tool you have is a hammer, to treat everything as if it were a nail.”    This blog addresses a methodology...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

Failure to Object to Untimely Interrogatories Coupled With a Discovery Violation Leads to Reversal

In Discovery Violation Requires New Civil Rights Trial Against Cop (bloomberglaw.com)(Jan. 3, 2024), Mr. Bernie Pazanowski reported on Morgan v. Tincher, No. 21-2060, __ F.4th __ (4th Cir. Jan. 3, 2024).  In short, plaintiff...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

Text Messages Used to Support Conviction: Prejudice Did Not Outweigh Probative Value

In Francois v. State, 2023 WL 8265659, at *1 (Apl. Ct. Md. Nov. 30, 2023), the defendant was charged with various offenses that included possession of a firearm and ammunition after a disqualifying conviction.  On appeal, the...more

Secondary Evidence of Missing Video Permitted

In Brooks-Anderson v. State, 2023 WL 3834829 (Apl. Ct. Md. Jun. 6, 2023)(unreported), defendant had been convicted of theft from Loomis Armored U.S., a cash transport company. The victim was the former-employer of the...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

Maryland Supreme Court Rejects Proposed Sanctions Rule Paralleling Fed.R.Civ.P. 37(e)

The Supreme Court of Maryland adopted an amendment to Maryland Rule 2-433, which governs sanctions in Maryland state courts. Amended Maryland Rule 2-433(b) abandons the shallow “safe harbor” rule....more

Court Uses an Informal Discovery Procedure to Hold That Untimely Objections Were Waived, and Answers to Interrogatories...

[EDRM Editor’s Note: This article was first published here on November 1, 2023 and EDRM is grateful to Michael Berman, for permission to republish. The opinions and positions are those of Michael Berman.] In three recent...more

Bob Dylan Awarded Discovery Sanctions After Dismissal of Tort Claims

“The Court awards sanctions in the amount of $5,000 against [Attorney No. 1] and $3,000 against [Attorney No. 2], payable to” Bob Dylan. J.C. v. Robert A. Zimmerman a/k/a Bob Dylan, 2023 WL 6308493, at *12 (S.D.N.Y. Sept....more

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