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Federal Rules of Civil Procedure Litigation Strategies Discovery Disputes

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

Array

This Week in eDiscovery: Why You Should Meet and Confer in Good Faith | Upcoming eDiscovery Webinar

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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 March 30-April 5. Here’s what’s...more

Minerva26

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

Kilpatrick

Crafting Customized ESI Agreements in E-Discovery: The Importance of Specificity of Document Production Formats

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In litigation, especially in dealing with E-Discovery, the importance of an effective electronically stored information agreement (“ESI Agreement”) between the parties is a must to help prevent discovery disputes. This is...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

Court Holds That an ESI Protocol Must be Specific in GenAI Copyright Class Action

In Andersen v. Stability AI Ltd., 2025 WL 870358 (N.D. Cal. Mar. 19, 2025), the court resolved a dispute over an ESI Protocol. The starting point was a Standing Order that, absent good cause, parties “shall use” one of the...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

Law School Toolbox

Bar Exam Toolbox Podcast Episode 305: Spotlight on Civil Procedure (Part 2 – Discovery)

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Welcome back to the Bar Exam Toolbox podcast! This is the second of three episodes in which we review the substantive Civil Procedure law we've covered in our "Listen and Learn" series.  This time we're talking about...more

JAMS

Discovery Special Masters and Referees: A View From Both Sides

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Having recently transitioned from being a litigator to serving as a discovery neutral, I've gained a distinct perspective on the role of discovery neutrals in our legal system. This experience has highlighted both the...more

Minerva26

One Court's Novel Approach to Addressing the Gap Between Search Term Hits and Produced Documents

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Effective management of discovery disputes is critical in litigation, particularly as courts enforce stricter adherence to discovery deadlines. A recent decision in Valeo Schalter und Sensoren GmbH v. NVIDIA Corp. highlights...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

Minerva26

Privilege Log, Privilege Log — It’s All About the Description

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A privilege log is the absolute bane of an attorney’s existence. I don’t mean it isn’t important and a critical component of discovery, but the level of planning, analysis and detail required to complete such a log is...more

Esquire Deposition Solutions, LLC

Poor Health, Family Obligations Supply Good Cause for Avoiding Deposition Travel

To their credit, experienced litigators are able to resolve the vast majority of pretrial discovery disputes without the need for court intervention. This is particularly true when the dispute in question is whether a...more

Nelson Mullins Riley & Scarborough LLP

Default Judgment Sanction Against Defendants for Failure to Produce Slack Messages

In Red Wolf Energy Trading, LLC v. BIA Capital Management, LLC, Gregory V. Moeller, Growthworks, LLC, Michael Harradon, and Jon Moeller, the United States District Court for the District of Massachusetts entered a default...more

Esquire Deposition Solutions, LLC

62-Hour Trek to Palau or Remote Deposition From Home? You Be the Judge

Palau is an island archipelago in the Pacific Ocean. The local economy depends on tourism, mainly from visitors interested in snorkeling and scuba diving along its beautiful barrier reefs. Tourism aside, the Palau economy is...more

Proskauer - Minding Your Business

Key Takeaways from the Amendment to Rule 30(b)(6)

This past year has brought lots of change, including an amendment to Rule 30(b)(6) of the Federal Rules of Civil Procedure. Rule 30(b)(6) governs the deposition of an organization (e.g., a corporation or a partnership) and...more

Troutman Pepper Locke

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

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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

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