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Decision on How to Best Search for ESI – Court Orders ESI Protocol in “Epic of Dysfunctional Discovery,” With Unique Clawback Provision

E-Discovery LLC

There a producing party was ordered to expend 40 hours in responding and produce a good faith affidavit. That seems to be a Solomon-like resolution of the affidavit-of-counsel issue. The Court stands ready and willing to mediate such legitimate disputes. 17, 2025), citing Marens v. Carrabba’s Italian Grill, Inc.,