E-Discovery LLC

JULY 1, 2025

It is also not clear to me which party carried the burden of proof under the “apex doctrine.” One recent case placed the burden on the party claiming an exception to the doctrine. 2025 WL 176001, at *1 (cleaned up; citations and quotations omitted). That might also have circumvented the “apex” issue. Lambert , __ Md.

Objections

E-Discovery LLC

SEPTEMBER 22, 2024

Among them were: general principles of discovery; the role of counsel in self-collection; discovery on discovery; the date that the litigation hold was triggered; whether reasonable post-trigger steps were taken; curative sanctions under Fed.R.Civ.P. It insists that it is not conducting unchecked discovery.”

Discovery

E-Discovery LLC

MAY 20, 2025

May 5, 2025), addressed the important issue of apex depositions in the governmental context. Plaintiffs, a parent and a school-age minor, in a personal injury claim against a school system sought the depositions of nine high-ranking government employees. May 19, 2025)(deposition of CFO and Senior V.P. of private entity).

Depositions

Plaintiff Trial Lawyer Tips

OCTOBER 31, 2024

THREE PRIMARY DEFENSE CLAIMS __ __ __ PLAINTIFF PROOF OF CAUSATION __ DEFENDANT CAUSATION DEFENSE _ PRELIMINARY STATUS REVIEW  Review local rules regarding deadlines and requirements DISCOVERY REVIEW Interrogatories  Review defendant’s answers to interrogatories. Note incomplete answers for motion. Supplement if needed.

Cross-Examination

E-Discovery LLC

NOVEMBER 29, 2024

Discovery had been conducted for almost a year and the deadlines extended three times. Doe complained of alleged piecemeal document production and, after deposition, “grew concerned” that relevant documents had not been produced. 5, 2024); Discovery About Discovery – When Was Duty to Preserve Triggered?

Burden Of Proof