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FRCP 34 Request for Production

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Seeking Production in Native Format? Case Law Tips From MetLife Investors USA Insurance Co. v. Lindsey

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Over the last year, requests and productions of native-format documents have featured regularly in ediscovery cases resolved by the courts. These cases have demonstrated how differently litigants—and judges—view the...more

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Case Law Summary: Native-Format Production — Lessons From McDonnel Group, LLC v. Starr Surplus Lines Insurance Co.

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With some electronically stored information (ESI), what you see is what you get. A simple screenshot, PDF, or TIFF image may convey all the information that a litigant needs....more

Association of Certified E-Discovery...

The Sedona Conference’s FRCP 34(b)(2) Primer

In March 2018,  The Sedona Conference published another useful guide for e-discovery professionals, Federal Rule of Civil Procedure 34(b)(2) Primer: Practice Pointers for Responding to Discovery Requests. This guide is the...more

Jones Day

Eastern District of Texas Latest Court to Criticize "Subject To" Language in Discovery Objections

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The Eastern District of Texas recently criticized a party's statement in its written discovery responses that it would produce documents "subject to" its objections. See Realpage, Inc. v. Enterprise Risk Control, LLC, No....more

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