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Litigation Strategies e-Discovery Professionals Federal Rules of Civil Procedure

Association of Certified E-Discovery...

Cracking the Code on ESI

The volume of “documents” relevant to litigation and government investigations has exploded due to electronic data, leading to a significant shift in the discovery process. What once required a trip to a client’s filing...more

EDRM - Electronic Discovery Reference Model

Standard for Court-Ordered Forensic Examinations – When Does Misconduct “Cross the Rubicon”?

A motion for a forensic examination was granted in PlayUp, Inc. v. Mintas, 2025 WL 2017161 (D. Nev. Jul. 18, 2025). On movant’s third try, the court found that the opponent was trying to “gaslight” the court and it granted...more

EDRM - Electronic Discovery Reference Model

Protective Order Barring Use of Discovery Materials in Other Litigation Was Vacated

[EDRM Editor’s Note: The opinions and positions are those of Michael Berman.] A protective order barring post-settlement use by plaintiffs’ counsel of defendant’s discovery responses in other litigation was vacated in Cordero...more

Cimplifi

Chess, Not Checkers: Negotiating from a Position of Power

Cimplifi on

ESI protocols have become an important tool for getting parties “on the same page” regarding how discovery will be conducted. While they aren’t necessarily appropriate for every case, they are a vital tool in helping to...more

EDRM - Electronic Discovery Reference Model

“This Was a Collective Debacle”

In Lacey v. State Farm General Ins. Co., 2025 WL 1363069 (C.D. Cal. May 5, 2025), plaintiff submitted a filing with erroneous AI-generated citations. The Special Master pointed out some of them. The plaintiff resubmitted a...more

EDRM - Electronic Discovery Reference Model

“It Ends With Us”

In Lively v. Wayfarer Studios LLC, 2025 WL 662896 (S.D.N.Y. Feb. 28, 2025), the court granted in part and denied in part a motion to quash subpoenas issued to AT&T, Verizon, and T-Mobile (the “Wayfarer Parties”) by Ms. Blake...more

EDRM - Electronic Discovery Reference Model

Court Holds That an ESI Protocol Must be Specific in GenAI Copyright Class Action

In Andersen v. Stability AI Ltd., 2025 WL 870358 (N.D. Cal. Mar. 19, 2025), the court resolved a dispute over an ESI Protocol. The starting point was a Standing Order that, absent good cause, parties “shall use” one of the...more

Kilpatrick

It’s all in the Details: Text Messages and The Importance of Detailed ESI Agreements

Kilpatrick on

Document collection and production now involves more than just sending opposing counsel emails. As business communication has evolved, so has the need for producing from various and evolving streams of communication. Text...more

EDRM - Electronic Discovery Reference Model

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

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

Minerva26

The Perils of Self-Collection in eDiscovery: What Litigators Need to Know

Minerva26 on

The risks of self-collection in ediscovery continue to be a central theme in courts across the country. A decision from Magistrate Judge William Matthewman in the Southern District of Florida, EEOC v. M1 5100 Corp., serves as...more

Association of Certified E-Discovery...

Negotiating the Scope of E-Discovery: Proportionality and Pre-Trial Preparation in Complex Litigation

I was fortunate to moderate a webinar for ACEDS about proportionality and summarize the discussion below. You can listen to the entire program here. Proportionality in e-discovery is based on the objective of Rule 1 of the...more

Esquire Deposition Solutions, LLC

Regarding Depositions Seeking Meta-Discovery

Experienced litigators are familiar with the tension between the federal legal system’s policy favoring liberal pretrial discovery into all relevant matters and the countervailing policy forbidding discovery that is...more

Buckingham, Doolittle & Burroughs, LLC

Avoiding Trials on Social Media: Obtaining protective orders to prevent trying your case on social media (or online)

Discovery can be a harrowing and intrusive process for all litigants. As federal and state rules allow for broad discovery of information relevant to any party’s claims or defenses, individuals and business are compelled to...more

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