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Discovery 101 – Court Sets Out Ground Rules to Resolve Discovery Dispute

E-Discovery LLC

5] “The rules also require objections to interrogatories and requests for production of documents to be made with specificity.” [6] 7] “Boilerplate objections are legally meaningless and amount to a waiver of an objection.” [8] 7] “Boilerplate objections are legally meaningless and amount to a waiver of an objection.” [8]

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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. Therefore, in the absence of any reasoned approach by counsel to these questions, we will address these issues for the parties. 2000)(Grimm, J.).

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“Heartless” Ex Parte Motion for Sanctions Denied Because There Was No “Fire”

E-Discovery LLC

After several extensions of time and meet-and-confers, defendants responded with only objections. After more attempts to resolve the matter, plaintiffs moved to compel. The West court wrote: “Saying that Kanye West is an artist who doesn’t really care about money and doesn’t really keep records is not an adequate excuse.

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Privilege Log Deemed Partially Inadequate

E-Discovery LLC

12, 2024); No Privilege Log Is Needed While Scope of Discovery Objections Are Pending (Aug. 28, 2024); Privilege Objections Denied Without Prejudice (Nov. 28, 2024); Privilege Objections Denied Without Prejudice (Nov. Specific objections are required.”). Logs should assert privilege with specificity.

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

E-Discovery LLC

Columbia submitted an affidavit stating that the protective order had a “tremendous chilling effect” on its advocacy in other matters. The exception is for attorneys “aggrieved” by an order or judgment: “To have standing, attorneys must show injury to themselves rather than to their clients.”

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No Privilege Log is Necessary in Limited Circumstances When Discovery Requests Are Overbroad

E-Discovery LLC

12, 2024); No Privilege Log Is Needed While Scope of Discovery Objections Are Pending (Aug. Both Mr. Hall and MAIP objected to the subpoena on a number of bases. The Hall Court added that Plaintiff and MAIP timely asserted privilege in their objections to the subpoena. at *11 (Emphasis added). See generally Fed.

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Golden Oldie #2 – 40 Hours of Searching is Enough

E-Discovery LLC

The Court addressed a number of issues, including the need for particularized objections and a sufficient privilege log. Second , the Court noted that defendants objection was conclusory: Although the information sought, arguably, is relevant to plaintiff’s claims, the scope of information sought is far too great.