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EDRM - Electronic Discovery Reference Model

ESI Protocol Should Define “Documents” and Address Redaction Based on Irrelevancy

We the Protestors, Inc. v. Sinyangwe, 348 F.R.D. 175 (S.D.N.Y. Dec. 18, 2024), makes several important points about the relationship between ESI Protocols and redaction of produced documents....more

Array

This Week in eDiscovery: ESI Protocol Stops “Dump Truck” Production | Modern Attachment Challenges and Solutions

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the period of April 13-19. Here’s what’s...more

EDRM - Electronic Discovery Reference Model

Uber Technologies – Another Hyperlink Decision

In In Re: Uber Technologies, Inc. Passenger Sexual Assault Litigation, 2025 WL 678543 (Mar. 3, 2025), the court issued another hyperlinked document discovery decision arising out of the parties’ ESI Protocol.  While...more

Lasher Holzapfel Sperry & Ebberson PLLC

Discovery: Civil Litigation’s Fact-Finding Mission – Part 1: Interrogatories

If you find yourself involved in civil litigation of any kind, the case will take up a significant part of your life. While your attorney will take on the heavy lifting, he or she will require your help to gather the facts...more

EDRM - Electronic Discovery Reference Model

Privilege Logs, Null Sets, Search Strings, and Number of Custodians in One Decision

The decision in Cook v. Meta Platforms, Inc., 2024 WL 251942 (N.D. Cal. Jan. 21, 2025), packs a lot into very few pages.  In two instances, where Meta had offered a compromise solution, the court held Meta to that offer....more

Minerva26

Can Parties Redact Text Messages for Relevance in Discovery?

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In today's fast-paced litigation landscape, electronically stored information (ESI) plays a critical role in shaping legal strategies and outcomes. Among the myriad sources of ESI, text messages have emerged as a critical...more

Association of Certified E-Discovery...

The Critical Role of Manner of Production in Litigation

Last week’s decision in Partners Insight, LLC v. Gill (M.D. Fla., October 28, 2024) tackles an often-overlooked yet essential aspect of ediscovery: manner of production. While much of our focus in ediscovery tends to be on...more

EDRM - Electronic Discovery Reference Model

November’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published December 4, 2024, and EDRM is grateful to Tom Paskowitz of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the author.]...more

Sands Anderson PC

Don’t Let the Document "Speak for Itself": Lessons from Lorenz v. Parker

Sands Anderson PC on

Before the Super Bowl, there are preseason drills; before the masterpiece, there are endless sketches. And before the trial, there is discovery. It is in these detailed, often overlooked moments that cases are won or lost....more

Association of Certified E-Discovery...

How the Default Settings for the Deletion of Text Messages Can Impact Sanctions

In Safelite Grp., Inc. v. Lockridge, the U.S. District Court examined whether a cease-and-desist letter triggers a duty to preserve electronically stored information (ESI) and how routine deletion of text messages impacts...more

Association of Certified E-Discovery...

[Event] eDiscovery Convergence 2024: From Basics to Breakthroughs in eDiscovery - November 20th, Toronto, ON, Canada

Join Us for eDiscovery Convergence 2024! This event is proudly hosted by the Ontario Digital Evidence and eDiscovery Working Group (DEED) and the Toronto Chapters of The Association of Certified eDiscovery Specialists...more

EDRM - Electronic Discovery Reference Model

Court-Ordered Production of a “Destruction/Unavailable” Log

I have never heard of a “destruction/unavailable” log; however, in the comprehensive – indeed, exhaustive – decision of Leprino Foods Co. v. Avani Outpatient Surgical Center, Inc., 2024 WL 4488711 (C.D. Ca. Sep. 30, 2024),...more

Stoel Rives LLP

The Importance of Staying Organized for Discovery

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Most companies, hopefully, have a low risk of litigation. However, when litigation is unavoidable, it is important to be as prepared as possible to mitigate expenses and potential liability. Discovery—the process of...more

Association of Certified E-Discovery...

Are Hyperlinked Files the Same as Attachments? A Court Weighs In on eDiscovery Challenges

A recent decision from the Northern District of California, UAB “Planner5D” v. Meta Platforms, Inc. addresses a growing challenge in ediscovery: whether hyperlinked files embedded in emails and other documents are the same as...more

EDRM - Electronic Discovery Reference Model

Self-Collection, Discovery About Discovery, and Curative Sanctions

EEOC v. Formel D USA, Inc., 2024 WL 4172527 (E.D. Mich. Sept. 12, 2024), addressed several interesting issues. Among them were: general principles of discovery; the role of counsel in self-collection; discovery on discovery;...more

Association of Certified E-Discovery...

Worried About Waiving Privilege via Inadvertent Production? You’ll Want to Read This.

In this week’s Case of the Week, I dive into a critical decision from FTC v. Amazon.com, Inc. (August 1, 2024), which underscores the precarious nature of privilege in document production—particularly in the context of...more

EDRM - Electronic Discovery Reference Model

August’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published August 21, 2024 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of...more

EDRM - Electronic Discovery Reference Model

July’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published July 24, 2024 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the...more

EDRM - Electronic Discovery Reference Model

The Standard for In Camera Review of Assertedly Privileged Documents

The purpose of a privilege log is to provide sufficient information for the recipient of the log to determine whether the withheld information is, at least on its face, privileged.  In short:  “Trust, but verify.”  See,...more

EDRM - Electronic Discovery Reference Model

Garden Variety: Byte Fed. v. Lux Vending

My esteemed colleagues, Kelly Twigger and Doug Austin, both posted about a recent discovery decision out of a federal district court in Florida, case no. 8:23-cv-102-MSS-SPF, styled, Byte Fed., Inc. v. Lux Vending LLC. and...more

EDRM - Electronic Discovery Reference Model

June’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published June 18, 2024 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the...more

EDRM - Electronic Discovery Reference Model

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

EDRM - Electronic Discovery Reference Model

April’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published April 17, 2024 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the...more

EDRM - Electronic Discovery Reference Model

General Data Protection Regulation Guidelines

Parties that have possession, custody, or control of evidence potentially relevant to U.S. litigation or investigations are typically required to identify, collect, preserve, and produce such evidence (with limited...more

EDRM - Electronic Discovery Reference Model

Cloud Attachments: Versions and Purview

[EDRM Editor’s Note: The opinions and positions are those of Craig Ball. This article is republished with permission and was first published on April 8, 2024.] Last week, I dug into Cloud Attachments to email, probing the...more

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