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Discovery Litigation Strategies Employment Litigation

Minerva26

BYOD Battle Lines: What Allergan v. Revance Teaches About Discovering Evidence on Employees’ Personal Phones

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Does your bring-your-own-device (BYOD) policy quietly wall-off the best evidence in your next case? A March 17, 2025 Special-Master ruling in Allergan, Inc. v. Revance Therapeutics, Inc. says it might—denying a motion to...more

Minerva26

How Failing to Meet and Confer Effectively Can Lead to Sanctions

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If you’ve been around the ediscovery space long enough, you’ve likely heard the term “drive-by meet and confer.” It’s what happens when counsel shows up to a Rule 26(f) conference unprepared, without the necessary knowledge...more

EDRM - Electronic Discovery Reference Model

How Not to Negotiate an ESI Protocol? Say it is “Mandatory”; and, Demand That Discussions be Recorded

In Wilbert v. Pyramid Healthcare, Inc., 2025 WL 873947 (W.D. Pa. Mar. 20, 2025), the court wrote: From the inception of this action, Counsel for the parties could not agree on the scope and methodology for ESI discovery…....more

Fox Rothschild LLP

A Corporate “One Man Band” Might be a Lonely Road, but the Company is Not Always a Puppet

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Matthew Bagley worked for a claims adjustment firm in Louisiana as its claims manager for nearly three years before resigning to, allegedly, improperly compete against his former employer, M.D. Claims Group. In M.D. Claims...more

Kilpatrick

Blurred Lines: Personal Devices, Proportionality, and Piercing the Work Product Privilege

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In a fairly short opinion and order, the district court in Weston v. DocuSign, Inc. analyzed whether the parties were entitled to the production of text messages from former employees’ personal devices and potential piercing...more

Esquire Deposition Solutions, LLC

How Many Depositions Are Enough?

Ten is the presumptive upper limit on the number of depositions that each party may take in civil litigation in the federal courts. This number, provided by Rule 30(a)(2) of the Federal Rules of Civil Procedure, can be...more

Perkins Coie

Washington Evaluates the Standard for Corporate Executive Depositions

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The Washington Supreme Court recently considered whether it would adopt the "apex doctrine." This doctrine is a framework used by some courts to evaluate whether a party may take the deposition of a company's executives and...more

Stoel Rives - Notice of Appeal

Washington Supreme Court Unanimously Rejects the Apex Doctrine

In Stratford v. Umpqua Bank, No. 100717-5 (Sept. 14, 2023) (slip op.), the Washington Supreme Court rejected the application of the “apex doctrine” in Washington. The apex doctrine has been adopted by some jurisdictions to...more

Butler Snow LLP

The Apex Doctrine and the C-Suite Deponent

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The First Line of Defense Against Plaintiff Overreach - The suit has been filed, the troops have been marshaled, and written discovery is underway. What’s next are the inevitable requests for depositions of current and...more

Littler

Florida Adopts the Apex Doctrine in the Corporate Context

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Late last month, the Florida Supreme Court codified into Florida Rule of Civil Procedure 1.280(h) the “apex doctrine” and declared the doctrine applies with equal force to high-ranking corporate and government officials....more

Bailey & Glasser, LLP

Strong Litigation Strategy Requires Updated Policies for Remote Workers

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Instant messaging apps and online workspaces offer collaboration and production capabilities for teams dispersed by COVID-19, but they also pose a danger to companies operating in reasonable anticipation of litigation, with...more

Seyfarth Shaw LLP

Request For Employment Records? Don’t Trust; Verify!

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Seyfarth Synopsis: Plaintiffs’ lawyers routinely invoke Labor Code provisions to conduct pre-litigation discovery by seeking employment records. For employers that scramble to comply with these often burdensome demands, we...more

Seyfarth Shaw LLP

Seyfarth Shaw Submits Comments On Needed Reform To Rule 30(b)(6)

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Seyfarth Synopsis: Seyfarth Shaw submitted comments to the Federal Advisory Committee on Civil Rules regarding needed reform to Rule 30(b)(6), the rule that governs depositions of organizations in federal litigation. ...more

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