Based on the ESI Protocol, the Limiting “Apex Deposition” Doctrine Applied to Objections to the Designation of a Document Custodian
E-Discovery LLC
JULY 1, 2025
45 subpoena duces tecum could not have been served on the non-party document custodian and avoided the designation issue. 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. Lambert , __ Md.
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