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EDRM - Electronic Discovery Reference Model

Another Approach to Drafting and Discovery of Litigation Hold Notices

EDRM - Electronic Discovery Reference Model on

By definition, a litigation hold notice is a communication from an attorney to a client regarding the duty to preserve potentially responsive information. In Homeland Ins. Co. of Del. v. Independent Health Ass’n., Inc., 2025...more

EDRM - Electronic Discovery Reference Model

Is Marking Documents as “Work Product” an Admission that the Duty to Preserve is Triggered?

EDRM - Electronic Discovery Reference Model on

In Stuart v. County of Riverside, 2024 WL 3086634, at *3 (C.D. Cal. Jun. 14, 2024), the District Court found a relationship between work product designations and triggering of the common-law duty to preserve....more

EDRM - Electronic Discovery Reference Model

Discovery About Discovery – When Was Duty to Preserve Triggered?

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In Linet Americas, Inc. v. Hill-Rom Holdings, Inc., 2024 WL 3425795 (N.D. Ill. Jul. 15, 2024), the court “allowed [defendants] Hillrom to take limited discovery about when [plaintiff] Linet’s duty to preserve may have...more

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