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e-Discovery Sanctions Motion to Compel

EDRM - Electronic Discovery Reference Model

Fed.R.Civ.P. 26(g) Was Violated by Permitting Client Searches With Minimal Oversight by Counsel

Fed.R.Civ.P. 26(g) is called the “stop and think” rule.  In Grullon v. Lewis, 2025 WL 1693425 (S.D.N.Y. Jun. 17, 2025), the court found a violation of that rule....more

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eDiscovery Case Law Podcast: How Failing to Meet and Confer Effectively Can Lead to Sanctions

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Magistrate Judge Scott Hardy delivers a masterclass on what the meet-and-confer requirement really means in federal litigation—and the serious consequences of failing to cooperate in discovery. In this riveting breakdown of...more

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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

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