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We Hold These Rules to Be Self-Evident: Document Review, Relevance, and the Federal Rules of Civil Procedure

Sometimes, an argument or position may seem so self-evident or apparent that parties proceed on the assumption that it is correct without ever actually litigating the issue. Should a party decide to contest the issue,...more

Reluctance to Follow Salt River

In 2019, I co-authored an article published by the American Bar Association regarding the future of U.S. pretrial discovery involving European Union data following the decision by the United States District Court for the...more

A Game of Chicken? Setting Forth a Detailed TAR Review Protocol

What Is TAR? Technology assisted review, or TAR, “uses software that can be trained by a human being to distinguish between relevant and non-relevant documents.”...more

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