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Electronically Stored Information Federal Rules of Civil Procedure Video Recordings

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

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Using Video Deposition Testimony for Opening Statements & Closing Arguments

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Trial advocacy is a mix of law and theater, requiring a lawyer to know both the law and their audience. Attorneys must effectively argue their client’s case using the evidence and the jury instructions to show their client is...more

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