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Local Rule Prohibiting Definitions in Interrogatories Without Leave of Court

E-Discovery LLC

The court cited a local rule that prohibits use of definitions in interrogatories without leave of court. Plaintiff Payne moved to compel discovery from Defendant Herman. In pertinent part, Herman objected to the definitions in Payne’s interrogatories. applies only to interrogatories. Emphasis added]. Sports Center Co.,

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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

In a case where the plaintiff seeks $24,000,000 in damages, the court stated: “Today we write the next chapter in this litigation, a case which threatens to become an epic of dysfunctional discovery…. The parties have long been embroiled in contentious discovery disputes.” Everlast Roofing , Inc. Wilson , 2025 WL 1959345 (M.D.

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Privilege Log Entry Was Relevant to Inquiry Notice Where Time-Bar Was at Issue

E-Discovery LLC

In Cáceres, privilege log entries appeared to show that plaintiffs were on notice of their claim months earlier than they asserted in interrogatory answers. The court also overruled an objection to the deposition of an SGR attorney. They sued for, inter alia , professional negligence in connection with tax advice. Emphasis added].

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Initial Disclosures Cannot Await Expert Opinions

E-Discovery LLC

It has also generated a cottage industry of discovery decisions. Westlaw lists 13 decisions (not all on discovery) since February 2025. Vasquez, Blake Lively’s Deposition Pushed Back by 2 Weeks After Judge’s Latest Ruling in Justin Baldoni Case (Jul. Wayfarer Studios LLC, 2025 WL 1999355 (S.D.N.Y. 14, 2025); I. 14, 2025); E.

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When Can a Party Refer to Produced Records as an Answer to an Interrogatory?

E-Discovery LLC

Plaintiff contended that, in response to plaintiffs interrogatories, Defendants improperly refer to hundreds of pages of documents, which is non-responsive, evasive, and in violation of Federal Rule of Civil Procedure 33(d). First, it must show that a review of the documents will actually reveal answers to the interrogatories.

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Two Recent Decisions Imposing Sanctions for Discovery Failures

E-Discovery LLC

26, 2024)(unreported), dismissals for discovery violations were affirmed. Nguh, one owner, propounded discovery on Mr. Etame, the opposing owner. The Appellate Court wrote: Mr. Etame failed to respond to discovery, and on March 3, 2022, Ms. Etame did not appear for his deposition on March 10, 2022. As a result, Ms.

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Discovery From Former Attorney About Disputed Quid Pro Quo Offer to Opponent

E-Discovery LLC

11, 2024), involved a request for discovery from a former Town attorney concerning an offer that he allegedly made to plaintiffs. The court: set out the governing standard for discovery from an attorney and, denied a request to depose the attorney; but, authorized a limited interrogatory to him.