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Motion to Compel Litigation Strategies Document Productions

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

Kilpatrick

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

Kilpatrick on

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

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

Payne & Fears

Nonparty Discovery in California Arbitration: How to Get What You Want

Payne & Fears on

Opting for arbitration requires attorneys to balance efficiency and procedural protections. The implications of arbitration are something clients certainly have to carefully consider both when drafting arbitration provisions,...more

Carlton Fields

Are the Bad Old Days of Blind Stonewalling in Discovery Finally Coming to a Close?

Carlton Fields on

When I started as a litigator in 2001, a technique I call “blind stonewalling” ruled discovery practice everywhere from BigLaw to the smallest boutiques. But the slow evolution of the Federal Rules of Civil Procedure (FRCP),...more

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