News & Analysis as of

Litigation Strategies Meet and Confer Discovery

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

Nextpoint, Inc.

Taking Depositions: Preparation Strategies for Attorneys

Nextpoint, Inc. on

TRIAL PREPARATION SERIES / PART TWO OF THREE - Taking depositions is arguably the most useful discovery exercise to gather information and build a strong case. It is the only opportunity, prior to trial itself, where an...more

Nextpoint, Inc.

Ediscovery Checklist: How to Win the Rule 26(f) Meet and Confer

Nextpoint, Inc. on

Preparing for the Meet and Confer - Proper preparation and documentation during the Rule 26(f) meet and confer process will greatly improve efficiency in the ediscovery phase of your litigation....more

Haug Partners LLP

Meet and Confer Requirements Added for Rule 30(b)(6) Depositions

Haug Partners LLP on

Rule 30(b)(6) of the Federal Rules of Civil Procedure, which concerns the use of a deposition notice or subpoena directed to an organization, was amended in December 2020 to require that parties meet-and-confer prior to...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

Farrell Fritz, P.C.

Critical Road Map for ESI in Litigation

Farrell Fritz, P.C. on

It is the beginning of a new year and I thought it the ideal time to list out those steps that are absolutely critical when an attorney is confronting his/her obligation to produce e-discovery in connection with a litigation....more

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