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Privileged Documents Discovery

EDRM - Electronic Discovery Reference Model

[Webinar] Important eDiscovery Case Law Decisions for April 2025 - April 28th, 1:00 pm - 2:00 pm ET

eDiscovery case law disputes are in full bloom! In our April 2025 monthly webinar of cases covered by the eDiscovery Today blog we will discuss disputes related to proportionality of discovery requests, lack of cooperation...more

McGuireWoods LLP

Court Confirms Basic Privilege Principles in Giving Princeton a Win

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Because litigants frequently take an aggressive approach when withholding documents on privilege grounds, courts’ in camera reviews often result in a loss for them. But sometimes courts agree with a litigant’s privilege...more

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[Webinar] Discovering Data Quickly in High-Stakes White-Collar Investigations - March 12th, 11:00 am - 12:00 pm CDT

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White-collar crimes present investigators with intricate challenges that require precision, expertise, and advanced technology. In today’s high-profile investigations, the stakes couldn’t be higher, with reputations,...more

EDRM - Electronic Discovery Reference Model

Another Approach to Drafting and Discovery of Litigation Hold Notices

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

McGuireWoods LLP

Assessing Privilege Protection for Training Materials and Presentations: Part II

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Last week’s Privilege Point described a court’s initial rejection but later acceptance of a county’s claim of privilege and work product protection for internal employee training. Hipschman v. Cnty. of San Diego, Case No....more

Minerva26

Podcast: Are Legal Holds Protected by Privilege? Insights from the FTC's Battle with Amazon

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Curious about whether legal holds are protected by privilege? You won't want to miss this week's breakdown of a landmark decision in the Federal Trade Commission versus Amazon case. We explore the intricacies of Amazon's...more

EDRM - Electronic Discovery Reference Model

Privilege Logs, Null Sets, Search Strings, and Number of Custodians in One Decision

The decision in Cook v. Meta Platforms, Inc., 2024 WL 251942 (N.D. Cal. Jan. 21, 2025), packs a lot into very few pages.  In two instances, where Meta had offered a compromise solution, the court held Meta to that offer....more

McGuireWoods LLP

When Can a Litigant Overcome the Adversary’s Fact Work Product Protection?

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Unlike the absolute attorney-client privilege (and the absolute or nearly absolute opinion work product doctrine protection), a litigant can overcome the adversary’s fact work product protection if it “shows that it has...more

McGuireWoods LLP

Court Adopts Variation of Bizarre Privilege Principle

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Several courts have adopted a nonsensical principle that, as one court put it, “[w]hen documents are prepared for dissemination to third parties, neither the document itself, nor preliminary drafts, are entitled to immunity.”...more

Epstein Becker & Green

Supreme Court of Ohio Rules on a Peer-Review Privilege Issue in Stull v. Summa

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Background - On December 10, 2024, the Supreme Court of Ohio issued its decision in Stull v. Summa, a medical negligence case in which the defendants argued that Ohio’s statutory peer-review privilege protected from...more

EDRM - Electronic Discovery Reference Model

November’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published December 4, 2024, and EDRM is grateful to Tom Paskowitz of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the author.]...more

Association of Certified E-Discovery...

[Webinar] How to Enhance Corporate Investigations on Apple Devices - August 22nd, 10:00 am PDT

Despite the dominance of Windows computers in corporate environments, an increasing number of companies are now integrating Apple Mac computers into their networks. Alongside this shift, the rise of BYOD (Bring Your Own...more

EDRM - Electronic Discovery Reference Model

The Standard for In Camera Review of Assertedly Privileged Documents

The purpose of a privilege log is to provide sufficient information for the recipient of the log to determine whether the withheld information is, at least on its face, privileged.  In short:  “Trust, but verify.”  See,...more

McGuireWoods LLP

The Consequences of a Bad or Tardy Privilege Log

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Every court seems to require litigants to log documents they withhold based on privilege or work product claims. Perhaps not surprisingly, hardly any log goes unchallenged by the adversary. Most of these disputes eventually...more

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Court Takes Expansive View of an Implied Waiver: Part II

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Last week’s Privilege Point described an opinion requiring a corporate party’s witness to disclose communications with his Latham & Watkins lawyers, because he confirmed with that firm his own “commercial understanding” about...more

McGuireWoods LLP

The Worrisome Nature of “Discovery About Discovery”

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Aggressive plaintiffs sometimes try to generate a “side show” by challenging corporate defendants’ discovery responses (usually their document productions). Although federal courts have thankfully moved in the direction of...more

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Courts Disagree About Privilege Log Requirements: Part II

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Last week’s Privilege Point described one court’s incredible requirement that litigants identify everyone who learned of a withheld document’s content — even if they were not shown as a recipient....more

EDRM - Electronic Discovery Reference Model

March’s Notable Cases and Events in E-Discovery

This Sidley Update addresses the following recent developments and court decisions involving e-discovery issues: 1. an order from the U.S. District Court for the Eastern District of California granting a motion to compel...more

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[Webinar] Getting Things Done with GAI - March 27th, 1:00 pm - 2:00 pm EDT

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We stand at the leading edge of a new wave of AI-enabled eDiscovery. In this webcast, we’ll explore how generative AI is transforming products and services for legal professionals....more

McGuireWoods LLP

Where Should Lawyers Look for the Applicable Attorney-Client Privilege?

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The attorney-client privilege originated in Roman law, and flourished under what John Adams labeled "that most excellent monument of human art, the common of law of England." But in America, some states articulate their key...more

Goodell, DeVries, Leech & Dann, LLP

Taking Discovery Obligations Seriously

Default judgments as a sanction for discovery violations are rare. Egregious conduct and failure to comply with multiple court orders usually precede the entry of a default judgment. Originally published in The Daily...more

Association of Certified E-Discovery...

[Webinar] The Pivotal Moment in the Narrative of eDiscovery: Unveiling AUTONOMOUS REVIEW by Altumatim - August 16th, 1:00 pm -...

Join us as we turn the page on traditional eDiscovery with AUTONOMOUS REVIEWTM, Altumatim's game-changing, AI-powered solution that is rewriting the story of how law firms, corporations, and other organizations conduct legal...more

Association of Certified E-Discovery...

Technocat Tidbits: What is Document Review for eDiscovery?

What is Document Review for eDiscovery? Let’s dive into the captivating realm of Electronic Discovery (eDiscovery) document review! (No, I am not being sarcastic!) This critical stage involves examining gathered documents to...more

EDRM - Electronic Discovery Reference Model

Using Special Masters and Discovery Mediators to Avoid and Resolve Discovery Disputes

Federal and state rules of civil procedure are intended to secure the just, speedy and inexpensive determination of every action. However, one activity that can thwart that goal is discovery, because the discovery process is...more

Vinson & Elkins LLP

Reducing Costs of Privilege Review and Privilege Logging

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The difficulty of handling privilege disputes can be especially pronounced in cases involving a prolonged discovery period and large corporate defendants with different document custodians. When a party chooses to withhold...more

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