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Litigation Strategies Federal Rules of Civil Procedure Evidence

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

Cimplifi

Chess, Not Checkers: Negotiating from a Position of Power

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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

Kerr Russell

Five Tips for Preparing to Testify at a Deposition

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Preparing for a deposition can be challenging whether it is a person’s first or hundredth time testifying under oath. Being questioned frequently causes anxiety. But the experience does not have to be so daunting with...more

Array

This Week in eDiscovery: How a ‘Diligent Search’ is Not a ‘Reasonable Inquiry’ and Why it Matters

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the period of June 8-14. Here’s what’s...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

Minerva26

BYOD Battle Lines: What Allergan v. Revance Teaches About Discovering Evidence on Employees’ Personal Phones

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Does your bring-your-own-device (BYOD) policy quietly wall-off the best evidence in your next case? A March 17, 2025 Special-Master ruling in Allergan, Inc. v. Revance Therapeutics, Inc. says it might—denying a motion to...more

Array

This Week in eDiscovery: Why You Should Meet and Confer in Good Faith | Upcoming eDiscovery Webinar

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the period of March 30-April 5. Here’s what’s...more

Law School Toolbox

Bar Exam Toolbox Podcast Episode 305: Spotlight on Civil Procedure (Part 2 – Discovery)

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Welcome back to the Bar Exam Toolbox podcast! This is the second of three episodes in which we review the substantive Civil Procedure law we've covered in our "Listen and Learn" series.  This time we're talking about...more

Minerva26

Why Skipping Initial Disclosures Can Cost You the Case

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Litigators, take note—Rule 26(a) is not just a box to check in the early stages of discovery. Failing to comply with its initial disclosure requirements can have disastrous and expensive consequences, as U.S. Bank recently...more

Pagefreezer

eDiscovery Costs: Social Media Evidence & The $90,000 Lesson

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These days, ignoring social media evidence in investigations and litigation is akin to leaving a crucial witness unquestioned. But as the case of Federico v. Lincoln Military Housing demonstrates, navigating this terrain can...more

Farrell Fritz, P.C.

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

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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

Esquire Deposition Solutions, LLC

The Apex Doctrine and Remote Depositions

The apex deposition doctrine is a judge-made rule that protects company executives from harassing, repetitive depositions in cases in which the executive has little relevant evidence to provide. Courts applying the doctrine...more

Esquire Deposition Solutions, LLC

AI Expert’s Report Deemed Unreliable Due to “Hallucinations” Within

“The irony.” So wrote federal district judge Laura M. Provinzino when she rejected as unreliable an artificial intelligence expert’s report that was found to have contained three non-existent, AI-generated citations. The...more

Montgomery McCracken

Recent Third Circuit Opinion Reinforces That Daubert Requires Courts to Examine the Data Underlying an Expert’s Analysis

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February 11, 2025 Types : Alerts Meta Platforms, Inc. recently defeated certification of a class of consumers who claim the company lied about its user privacy safeguards and violated antitrust laws. ...more

Esquire Deposition Solutions, LLC

New Minnesota Rule Removes Roadblocks to Remote Depositions

Revised Minnesota pretrial discovery rules, which took effect Jan. 1, now encourage remote depositions by allowing them to be set by notice alone. Former practice required either a court order or stipulation....more

Morgan Lewis

Expert Testimony May Be Limited if ‘Confidential’ Information Is Withheld Under Section 6103

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Expert witnesses can be critical to defending a tax position—but what happens when an expert must maintain confidentiality over information that is important to their analysis? Preserving this confidentiality while ensuring a...more

Lasher Holzapfel Sperry & Ebberson PLLC

Discovery: Civil Litigation’s Fact-Finding Mission – Part 1: Interrogatories

If you find yourself involved in civil litigation of any kind, the case will take up a significant part of your life. While your attorney will take on the heavy lifting, he or she will require your help to gather the facts...more

U.S. Legal Support

Preparing an Effective Notice of Deposition

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Noticing a deposition is a critical part of the litigation process. Far from just a formality, it’s an assurance that a deposition you’re engaging in is being done fairly and in good faith. By giving all interested parties...more

Foley & Lardner LLP

You’ve Been Sued: Now What?

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Being served with a lawsuit is frustrating, and sometimes nerve-racking, even for seasoned in-house counsel. Having a plan in place to quickly and appropriately address new lawsuits can ease the stress of being sued....more

TransPerfect Legal

From Paper to Pixels: The Evolution and Power of eDiscovery in Modern Legal Practice

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We live in an era of ‘big data.’ According to the International Telecommunications Union, more than three-quarters of the world’s population own a mobile phone. The same statistics apply for computer and internet use....more

Esquire Deposition Solutions, LLC

Sanctioning Deposition No-Shows in 2025

The blog post Turning Deposition No-Shows to the Client’s Advantage proved popular with our readers when written (2021!) and for years afterward. The sustained readership of that article is gratifying but also disappointing...more

Minerva26

Can Parties Redact Text Messages for Relevance in Discovery?

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In today's fast-paced litigation landscape, electronically stored information (ESI) plays a critical role in shaping legal strategies and outcomes. Among the myriad sources of ESI, text messages have emerged as a critical...more

Constangy, Brooks, Smith & Prophete, LLP

Robin's quickie guide to motions to dismiss, summary judgment, and trial

What's the difference? There are three main ways for a defendant to bring a lawsuit to an end. Each involves a different level of proof – and of expense and hassle. It's better to get a lawsuit “disposed of” as early as...more

Minerva26

Privilege Log, Privilege Log — It’s All About the Description

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A privilege log is the absolute bane of an attorney’s existence. I don’t mean it isn’t important and a critical component of discovery, but the level of planning, analysis and detail required to complete such a log is...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

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