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EDRM - Electronic Discovery Reference Model

Application of Work-Product Doctrine to Materials Prepared Years After Incident

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In Hall v. Baltimore Police Dept., 2025 WL 1548560 (D. Md. May 30, 2025)(Austin, J.), the Court considered whether materials created many years after the underlying incident were protected under the work-product doctrine. The...more

EDRM - Electronic Discovery Reference Model

Authentication of Surveillance Video by Lay Witness Under Silent Witness Doctrine

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In Reddick v. State, __ Md. App __, 2024 WL 4633506 (Apls. Ct. Md. Oct. 31, 2024), the intermediate appellate court addressed an important issue of authentication of surveillance video by a lay witness. That witness was...more

EDRM - Electronic Discovery Reference Model

An Epilog: 4 Things You Never Wanted to Hear + 8 Lessons & a Dispute Over Revealing Recipients of Litigation Hold Notices, All in...

EDRM - Electronic Discovery Reference Model on

I have posted five blogs – – with links below – – on In Re: Social Media Adolescent Addiction/Personal Injury Products Liability Litigation, 2024 WL 1786293 (N.D. Cal. Feb. 20, 2024), subsequent opinion, 2024 WL 1808607 (N.D....more

U.S. Legal Support

AI’s Role in Deposition Preparation & Analysis

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There’s no denying it—artificial intelligence is changing the legal landscape. Generative AI and the use of machine learning promise to boost efficiency and reduce prep time through multiple phases of litigation.  For...more

EDRM - Electronic Discovery Reference Model

Authentication of Entire Video When Witness Observed Only Part of the Events Portrayed in the Video

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Can a witness authenticate a video if the video contains images that the witness did not see?  In Md. Supreme Court to rule on Baltimore criminal case involving video authentication – Maryland Daily Record...more

EDRM - Electronic Discovery Reference Model

Lawyer Refused to Appear on Camera in Virtual Deposition

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In Client escapes sanction for lawyer’s refusal to appear on camera in Zoom deposition (abajournal.com)(Jan. 25, 2024,), Debra C. Weiss reported on Agnone v. Agnone, 2024 WL 242488 (Cal. App., 2d Dist., Jan. 23,...more

EDRM - Electronic Discovery Reference Model

If You’re Going to Coach a Witness and Misrepresent it to the Court, Turn Off the Recorder

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In Hernandez v. La Fortaleza, Inc., 2024 WL 65217 (N.J. Super. Ct. App. Div. Jan. 5, 2024)(per curiam), plaintiffs’ slip and fall claim was dismissed with prejudice, and attorneys’ fees were also awarded, due to improper...more

Esquire Deposition Solutions, LLC

The Five Types of Depositions That Flow from Obtaining ESI and E-Discovery - Part I

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Litigation counsel today routinely engage with large quantities of digital evidence, often with case outcomes turning on the advocate’s success at unearthing or preserving relevant electronically stored information (ESI). As...more

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