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Federal Rules of Civil Procedure › Video Recordings › Discovery

EDRM - Electronic Discovery Reference Model

How Not to Negotiate an ESI Protocol? Say it is “Mandatory”; and, Demand That Discussions be Recorded

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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

Esquire Deposition Solutions, LLC

Recent Rulings Highlight Importance of Depositions in Litigation

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In civil litigation, depositions are a key pretrial discovery tool used to uncover facts, obtain admissions, gather evidence for motions, and assess witnesses. They prevent “trial by ambush” by revealing crucial information...more

Esquire Deposition Solutions, LLC

Taxation of Deposition-Related Costs in Federal Courts

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As litigators know, the United States follows the so-called “American Rule” when apportioning the costs of litigation. Unless a statute specifically provides otherwise, parties in court are responsible for their own...more

Saiber LLC

District of New Jersey Grants Broad Sanctions, Stops Short of Dismissal, for Willful Withholding of Relevant Photos

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On April 20, 2023, Magistrate Judge Ann Marie Donio of the United States District Court for the District of New Jersey issued a comprehensive opinion concerning the appropriate level of sanctions for discovery misconduct. ...more

Esquire Deposition Solutions, LLC

62-Hour Trek to Palau or Remote Deposition From Home? You Be the Judge

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Palau is an island archipelago in the Pacific Ocean. The local economy depends on tourism, mainly from visitors interested in snorkeling and scuba diving along its beautiful barrier reefs. Tourism aside, the Palau economy is...more

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