News & Analysis as of

Federal Rules of Civil Procedure Discovery Motion to Compel

EDRM - Electronic Discovery Reference Model

No Sanctions for Resetting Two Cellphones on Facts Presented; and, Social Media Posts Supported Dismissal

In Wenzler v. U.S. Coast Guard, 2025 WL 1445805 (Mar. 20, 2025), Wenzler alleged that he had been disenrolled from the voluntary U.S. Coast Guard Auxiliary based on his speech on social media.  Wenzler unsuccessfully asserted...more

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

EDRM - Electronic Discovery Reference Model

Discovery Rulings in Abrego-Garcia v. Noem Deportation Case

In Abrego-Garcia v. Noem, __ F.R.D. ___, 2025 WL 1166402 (D. Md. Apr. 22, 2025)(Xinis, J.), plaintiffs notified the Court of “seemingly intractable discovery disputes….”  The case is before the District Court after the United...more

EDRM - Electronic Discovery Reference Model

An ESI Protocol Saved the Day for the Discovering Party

In Pincus Law Grp PLLC v. MJ Connections, Inc., 2025 WL 1070384 (E.D.N.Y. Apr. 9, 2025), the court ruled in favor of a discovering party and ordered reproduction of previously-produced documents under the terms of an ESI...more

Esquire Deposition Solutions, LLC

Failure to Schedule Depositions Together Was Discovery Abuse

Recent amendments to the federal rules governing pretrial discovery encourage courts to be more aggressive in squelching wasteful discovery practices. Litigators should be mindful that judges are increasingly taking the rules...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

McGuireWoods LLP

What If an Adversary Subpoenas Your Client’s Privileged Documents That Are in Someone Else’s Possession?

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Litigation adversaries often trigger privilege and work product disputes when they seek each other’s documents. But what if your client’s adversary subpoenas a third party holding your client’s privileged documents — whose...more

EDRM - Electronic Discovery Reference Model

September’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published September 25, 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...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

Sometimes Discovery Disputes Do Not Bring Out the Best in Us.

That is what makes the recent decision in M1 Holdings, Inc. v. Members 1st Fed. Credit Union, 2024 WL 182220 (N.D. Ill. Jan. 17, 2024), interesting.  Both of the disputing litigants were ordered to state under oath that they...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

Weintraub Tobin

Court Orders Monetary Sanctions after Plaintiff Fails to Provide any Response to Allegedly Overbroad Discovery Requests

Weintraub Tobin on

In Buergofol GmbH v. Omega Liner Company, Inc., 4-22-cv-04112 (DSD Jul. 13, 2023) (Karen E. Schreier), the court granted the defendant’s motion to compel and awarded monetary sanctions after the plaintiff failed to respond at...more

Nutter McClennen & Fish LLP

Practice Pointer: Under Massachusetts Procedure, There’s No Right to Expert Depositions

Under Massachusetts procedure, a party has the right to compel an opponent to disclose its testifying expert’s opinions through interrogatories. But unlike federal procedure, a party under Massachusetts procedure must obtain...more

Woods Rogers

Magistrate Judge Leonard holds that the FRCP Require Parties to Sign Authorizations

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As if subpoena practice is not expensive and time-consuming already, there are times in which even a subpoena will not suffice to obtain a third-party’s records.  Federal statutes may create confidentiality issues, or a state...more

Troutman Pepper Locke

What Is a 'Reasonably Useful Form' for Production of ESI?

Troutman Pepper Locke on

In our digital world, one might think that the production format of electronically stored information, or ESI, in civil litigation is no longer controversial, but recent court decisions make it clear that is not the case. ...more

Brooks Pierce

The NC Business Court Deals With The Apex Doctrine (Again)

Brooks Pierce on

I know that you haven’t heard from me in a while. I’m sorry, and I feel guilty. ......I’m not ready to abdicate my position as the original NC Business Court blogger, so I’m back at it again. My reentry point is the...more

Foley & Lardner LLP

Text Messages, EDiscovery, and the New Threat to Privacy

Foley & Lardner LLP on

Maybe some of you will look at the title of this article, smirk, and dismissively mutter that there is nothing new about text messages. eDiscovery practitioners also may think there is nothing revolutionary about considering...more

Sheppard Mullin Richter & Hampton LLP

Pursuing and Responding to Discovery Requests Under 28 U.S.C. § 1782

As discussed in a previous blog post, an interested party in a foreign or international proceeding may apply to a United States District Court for discovery from an individual or corporation who resides or is found in the...more

Farrell Fritz, P.C.

A Cooperative Discovery Process Promotes Efficient Advocacy

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In Youngevity Intl’s Corp. v. Smith (No: 16-cv-00704 [SD CA December 21, 2017]), defendants sought an Order pursuant to Federal Rules of Civil Procedure 26(g) and 37. The Order required Plaintiffs to remediate an improper...more

Farrell Fritz, P.C.

Judge Finds Defense Counsel’s Reliance upon Pre-Amendment Rule 26 in a Motion to Compel the Equivalent of Bad Faith – Resulting in...

Farrell Fritz, P.C. on

In Fulton v. Livingston Financial LLC, 2016 WL 3976558 (W.D. Wash. July 25, 2016), U.S. District Judge James L. Robart sanctioned a defense lawyer who “inexcusabl[y]” relied on outdated case law and pre-2015 amendments to...more

Bass, Berry & Sims PLC

Chris Lazarini Analyzes Right to Jury Under Section 4 of Federal Arbitration Act

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Bass, Berry & Sims Chris Lazarini analyzed a case outlining when a party is entitled to have a jury decide issues related to the making or enforceability of an arbitration agreement. ...more

Robinson+Cole Data Privacy + Security Insider

Proportionality makes a comeback

After seemingly endless years of rulemaking, the first decisions applying the amended Federal Rules of Civil Procedure have begun to trickle out. Not surprisingly, there have been no game changers to date, but early signs...more

McGuireWoods LLP

E-Discovery Update: Jury Still Out on Whether New Federal Rules Will Significantly Impact Discovery

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As noted in our December e-discovery update, the much-discussed amendments to the Federal Rules of Civil Procedure became effective December 1, 2015. One of the most notable amendments was the limitation on the scope of...more

Fish & Richardson

An Increased Emphasis on “Proportional Discovery”

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Magistrate Judge Grewal has denied a motion to compel discovery because the requests were “disproportionate,” alluding to the requirement in newly amended Rule 26(b)(1), F.R.Civ.P., that the discovery sought should be...more

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