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Litigation Strategies Commercial Court Discovery

Farrell Fritz, P.C.

Preparation Is Everything: Commercial Division Advisory Council Proposes New Model Pre-Trial Order for Trials in the Commercial...

Farrell Fritz, P.C. on

Regular visitors to this blog no doubt are aware that the rules of practice for the Commercial Division are centered on innovation, efficiency, cost-effectiveness, and predictability.  This includes the rules governing trial...more

Farrell Fritz, P.C.

Good Cause or Gamesmanship: A Review of “Good Cause” in the Commercial Division

Farrell Fritz, P.C. on

As my colleague, Matt Donovan, recently blogged, it is essential for litigants to “play[] nice in the litigation sandbox” or risk facing the ire of the Justices in the Commercial Division. Many litigants might think they are...more

Farrell Fritz, P.C.

Discovery Sanctions Alert: Failure to Include Withheld Items on Privilege Log Lands Party in Hot Water

Farrell Fritz, P.C. on

Commercial Division Rule 11-b governs a party’s obligation to produce a log of documents withheld on the basis of privilege.  Enacted in 2014, Rule 11-b substantially streamlines the privilege log process by encouraging...more

Farrell Fritz, P.C.

Updates to Commercial Division Rules Concerning Discovery of ESI

Farrell Fritz, P.C. on

As we approach the 30th Anniversary of New York’s Commercial Division, it’s fair to say that over those 30 years, the Commercial Division has held true to its aim of improving the efficiency and judicial treatment of complex...more

Farrell Fritz, P.C.

Even as Pandemic Wanes, Remote Depositions Remain the New Normal

Farrell Fritz, P.C. on

In March 2020, the New York State Courts and attorneys’ offices all over the state shut down as part of the public’s broad effort to slow the spread of the Coronavirus, and the legal profession quickly transitioned to remote...more

Farrell Fritz, P.C.

A Wave of E-Discovery Change: The Latest Proposal from the Advisory Council

Farrell Fritz, P.C. on

New York’s Commercial Division has continuously taken the lead as an innovative forum, proposing rule changes that are aimed at increasing efficiency and overall effectiveness of the litigation process. ...more

Farrell Fritz, P.C.

NY Practice Tip: Protecting Your Client Against an Improper Notice to Admit

Farrell Fritz, P.C. on

The CPLR 3123 notice to admit can be a useful device in litigation.  Its primary purpose is to expedite a trial by eliminating the necessity of proving a readily admittible fact or matter not in dispute. ...more

Farrell Fritz, P.C.

Pandemic Aftermath: The Rise Of Interstate Depositions And Discovery

Farrell Fritz, P.C. on

With global commerce massively affected by the COVID-19 pandemic, post-pandemic litigation will undoubtedly result in a rise of interstate depositions and discovery. In turn, litigants engaged in actions pending outside of...more

Farrell Fritz, P.C.

First Department Protective of High-Frequency Trading Algorithm: Considerations in Handling Discovery Requests for Propriety Code,...

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As we continue to see increased litigation over electronic programs, apps, and algorithms, courts are increasingly called to consider discovery requests for the coding behind that technology.  These requests highlight the...more

Farrell Fritz, P.C.

A Thoughtful Insight into Seeking a Stay of Proceedings

Farrell Fritz, P.C. on

“Should I stay or should I go”, queried the Clash.  Litigators are often faced with the same question, albeit in a far different context.  Most (but certainly not all!) Commercial Division practitioners try to move litigation...more

Nutter McClennen & Fish LLP

BLS Year in Review: Key Takeaways from the Judges

On June 11, the Boston Bar Association hosted its annual “Business Litigation Session Year in Review.” The BLS judges, including incoming Judge Brian Davis (who is taking over for Judge Leibensperger in BLS1), shared tips and...more

Farrell Fritz, P.C.

Not All “Repeated Discovery Failures” Lead to the Striking of a Pleading

Farrell Fritz, P.C. on

So you entered into a Preliminary Conference and a Compliance Conference Order with your adversary whereby the parties have to exchange discovery by dates certain. The purpose of these orders is to save parties a significant...more

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