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Discovery Electronically Stored Information Work-Product Doctrine

EDRM - Electronic Discovery Reference Model

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

EDRM - Electronic Discovery Reference Model

March’s Notable Cases and Events in E-Discovery

This Sidley Update addresses the following recent developments and court decisions involving e-discovery issues: 1. an order from the U.S. District Court for the Eastern District of California granting a motion to compel...more

Nextpoint, Inc.

Ediscovery Data Migration at Law Firms: A Modern Success Story

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Ediscovery Data Migration: Cloud to the Rescue - Foley & Mansfield, a national law firm based in Minneapolis, had been using a legacy, on-premise ediscovery platform for over a decade. When the vendor notified Foley &...more

Proskauer - Minding Your Business

NY Court Re-Affirms Privilege Protection for Personal Emails Sent by Law Firm Partner on Firm Email Account

Citing new deposition testimony, actor Justin Theroux in a recent motion asked the New York Supreme Court to reconsider its December 2020 denial of Theroux’s motion to compel production of emails that his neighbor, Norman...more

Reveal

Technology-Assisted Review (TAR) | Everything In-House Counsel Need to Know [Guide]

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Maybe you went into the law because you aren’t much of a tech person. You’re more of a big-picture thinker, hired as in-house counsel for your legal acumen, ability to strategize, and broad-based experience. You figure you...more

Esquire Deposition Solutions, LLC

Litigation Experts Encourage Wider Use of Privilege Protection Orders

Federal litigators aren’t taking sufficient advantage of 2008 amendments to Federal Rule of Evidence 502, which gives them the authority to obtain protective orders that can stem the damage from inadvertent disclosure of...more

Lighthouse

The Next Step is Now in Privilege Review.

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Looking beyond the keyword list paradigm as AI and analytics take the stage - In a 2012 True North blog post, one of our H5 experts provided some practical advice on reducing privilege review burdens and costs by...more

Husch Blackwell LLP

SB 224 Adopted: Missouri Discovery Rules Follow Federal Footsteps

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In 2019, the Missouri legislature passed Senate Bill 224 (SB 224), effectively revising Missouri’s discovery rules to align them with the Federal Rules of Civil Procedure. (See our 2019 post for analysis of SB 224’s changes...more

Kilpatrick

Right on Redactions

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In my experience as an e-discovery project manager, I’ve found that one of the primary reasons for lengthy document reviews is the need to redact documents. While the extent to which redactions will be needed may not be known...more

JAMS

Keeping the Dam From Breaking: Six ways a special master can help keep cases moving during the pandemic

JAMS on

Even though many courthouses across the country are empty or hearing only a limited number of cases due to the coronavirus pandemic, cases are still being filed. While the pandemic has affected the processing of cases,...more

Jackson Lewis P.C.

New Jersey Addresses Rising Use Of E-Discovery With ‘Safe Harbor’ For Inadvertent Disclosures

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Under an amendment to New Jersey Rule of Evidence (N.J.R.E.) 530 (Waiver of Privilege by Contract or Previous Disclosure), a “safe harbor” is available effective July 1, 2020, to clients and attorneys who inadvertently...more

McGuireWoods LLP

Illinois Courts Deal With Privilege Presumptions: Part I

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All courts agree that litigants asserting attorney-client privilege or work product protection must establish the protection's applicability. But courts take different positions on whether any presumptions guide their...more

Orrick, Herrington & Sutcliffe LLP

Influential Sedona Conference Releases Key Guidance for Attorney-Client Privilege and Work-Product Protection in Cybersecurity...

With significant input from Orrick’s Cybersecurity, Privacy and Data Innovation team, the influential Sedona Conference and its Working Group 11 last week published important guidance on the application of the attorney-client...more

Faegre Drinker Biddle & Reath LLP

Overview of Amendments to New Jersey’s Evidence Rules, Effective July 1, 2020

The increasing use of electronic discovery in litigation and the attendant high risk of inadvertent disclosures has led the New Jersey Supreme Court to adopt amendments to New Jersey’s Evidence Rule 530 (Waiver of Privilege...more

Husch Blackwell LLP

Toxic Tort Monitor: New Missouri Discovery Rules

Husch Blackwell LLP on

Recently, the Missouri legislature passed Senate Bill 224 outlining a brand new set of discovery rules for Missouri state-court cases. These new rules represent a comprehensive revision to the existing rules and make the...more

Kilpatrick

Just Because We Can, Doesn’t Always Mean We Should

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A recent North Carolina Court of Appeals decision exemplifies how an overreliance on technology in e-discovery can risk trampling on fundamental privileges and rights....more

Troutman Pepper Locke

Evaluating Stand-Alone Privilege for Cybersecurity Info

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With cybercrime on the rise, organizations have increasingly found themselves subject to litigation or regulatory investigations related to breaches. Documents and information created before breaches, such as security...more

Poyner Spruill LLP

North Carolina Court of Appeals Addresses eDiscovery Protocols

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Hard to believe, but it took until August 29, 2019 for the North Carolina Court of Appeals to tackle the issue of eDiscovery for the very first time. But tackle it the court did....more

Miller Canfield

Michigan Supreme Court Approves Significant Changes to Michigan Court Rules Effective January 1, 2020

Miller Canfield on

The Michigan Supreme Court has adopted proposed changes to several Michigan Court Rules, at the recommendation of the State Bar of Michigan Civil Discovery Rule Review Special Committee. Those changes take effect January 1,...more

Kilpatrick

My My, What Big Claws You Have! Navigating the Pitfalls of Drafting Clawback Agreements

Kilpatrick on

One of the greatest fears in any litigation matter is that you will somehow accidentally produce work product or attorney-client privileged documents to the opposing side and waive the privilege. As a result, it has become...more

McGuireWoods LLP

E-Discovery Update: Look Before You Post: Beware the Dangers of File-Sharing Sites

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In Harleysville Insurance Company v. Holding Funeral Home, Inc., et al., 2017 WL 4368617 (W.D. Va. 2017), an investigator for Nationwide, which owns Harleysville Insurance, uploaded a surveillance video of a fire scene to an...more

Skadden, Arps, Slate, Meagher & Flom LLP

The E-Discovery Digest - March 2018

The ninth edition of The E-Discovery Digest focuses on recent decisions addressing the scope and application of the attorney-client privilege and work-product doctrine, spoliation, and discovery responses....more

Mintz

Delaware District Court Finds No Work-Product or Common Legal Interest Protection for Certain Pre-Suit and Pre-Agreement Documents...

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Recently, the District of Delaware held that a there was no work-product protection, and no common legal interest protection covering communications and documents shared between a patent owner and a third-party litigation...more

McGuireWoods LLP

If a Court Decides That a Document Deserves Work Product Protection, Should the Court Also Deal With a Privilege Claim?

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Wise lawyers always consider both attorney-client privilege and work product protection when withholding a document or testimony. Privilege protection is absolute but fragile. Work product protection is qualified but...more

Epiq

2017 eDiscovery Case Law Review

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Electronic discovery cases that made headlines in 2017 featured well-known names such as Taylor Swift and Lynyrd Skynyrd, and reached all the way to the U.S. Supreme Court. As the year draws to a close, it’s a good time to...more

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