E-Discovery LLC

JULY 31, 2025

Plaintiff Payne moved to compel discovery from Defendant Herman. The Maryland Court published “Guidelines for Uniform Instructions and Definitions for Use in Discovery Requests.” Both approaches seem focused on the same goal – avoiding unreasonable, lengthy, convoluted definitions to discovery requests. Union Pac.

Interrogatories

E-Discovery LLC

JULY 14, 2025

”Applying the clear and convincing standard, Amazon’s withholding of almost 70,000 documents until the eve of, and after, the April 25, 2025 discovery cutoff—including the documents identified above—was tantamount to bad faith.” The issue was whether Amazon acted in bad faith during discovery. Discovery closed on April 25, 2025….

Discovery

E-Discovery LLC

JULY 26, 2025

37-3 states: Unless the Court in its discretion otherwise allows, no discovery motions may be filed or heard on an ex parte basis absent a showing of irreparable injury or prejudice not attributable to the lack of diligence of the moving party. Plaintiff is concerned about the clock ticking on its discovery cutoff, and rightly so.

Discovery

E-Discovery LLC

JULY 6, 2025

Sidley moved to compel production of documents by a third party law firm, Smith, Gambrell & Russell LLP (“SGR”) and also “deposition testimony concerning the Cácereses’ communications with their attorneys about their potential claims against Sidley, including facts supporting such claims, which Plaintiffs and SGR have asserted are privileged.”

Interrogatories

E-Discovery LLC

JULY 11, 2025

The decision is one part of vigorously-litigated [1] discovery in a civil rights lawsuit. Defendants sought discovery of those materials, arguing that certain entries related to only “fact work product” that should be disclosed. The Court wrote: The distinction is critical to discovery disputes.

Witnesses

E-Discovery LLC

JULY 1, 2025

A motion to compel the designation of an “apex” non-party document custodian was granted in In Re Mosaic LLM Litigation , 2025 WL 176001 (N.D. In Re Mosaic LLM Litig., The limiting “apex doctrine” generally does not apply to document custodians. 2025 WL 1755650, at *1 (N.D. June 25, 2025). Mayor & City Council of Baltimore v.

Objections

Steno

JANUARY 6, 2025

Executive Summary Challenge: After decades of litigation experience, attorney Mike Marzban recognized that colleagues were often too shy to provide candid feedback on his deposition technique. He needed an objective way to evaluate his performance and identify potential blind spots in his questioning strategies.

Depositions

E-Discovery LLC

JULY 3, 2025

Second , it wrote that the duty to preserve “is triggered when litigation is reasonably anticipated.” That “also extends to that period before the litigation when a party reasonably should know that the evidence may be relevant to anticipated litigation.” Roberts was fired the next day. citation omitted].

Evidence

E-Discovery LLC

JULY 20, 2025

It has also generated a cottage industry of discovery decisions. Westlaw lists 13 decisions (not all on discovery) since February 2025. Contextually, the litigation has been described in popular media. Vasquez, Blake Lively’s Deposition Pushed Back by 2 Weeks After Judge’s Latest Ruling in Justin Baldoni Case (Jul.

Interrogatories

Percipient

MAY 30, 2025

It lays out the exact steps needed to complete something, like drafting a contract, onboarding a client, or preparing for litigation. Litigation Case Workflow Litigation work involves strict timelines, detailed documents, and coordination across teams. Book your discovery call today.

Legal Services

Planet Depos

JUNE 17, 2025

In addition to official court reporters who are employed by the courts and work inside the courtroom, there are freelance court reporters who provide services through the discovery phase of litigation for depositions. Why would an attorney schedule a videographer?

Depositions

E-Discovery LLC

JULY 22, 2025

It is argued that “immigration litigation has shifted to district courts” and that increased caseload created “the need for modest measures to assist them in addressing time-sensitive petitions for review,” especially given the administration’s efforts to execute removals “on an extraordinarily expeditious basis….” E-Discovery LLC (Jul.

Cross-Complaint

Law Sites

JULY 17, 2025

One of the areas of legal practice in which generative artificial intelligence is having a significant impact is litigation, bringing new products designed to handle the time-intensive work of conducting discovery, sifting through evidence, analyzing depositions and preparing for trial.

Depositions

E-Discovery LLC

AUGUST 9, 2024

24, 2024), “Plaintiff, Vernie Kent, seeks to compel Defendant, Kade Warner, to produce a surveillance video Defendant’s attorney prepared in conjunction with this litigation.” This blog was initially posted on Electronic Discovery Reference Model. Plaintiff, however, asserted a substantial need for it.

Depositions

E-Discovery LLC

DECEMBER 18, 2024

Plaintiffs wanted more information about (1) whether Google preserved chat messages for Mr. Boyer and other witnesses; (2) whether Google timely implemented a litigation hold for custodial documents for Mr. Boyer and other witnesses; and (3) whether Mr. Boyer and other witnesses participated in Googles communicate with care trainings.

Discovery

WA Bar News

NOVEMBER 12, 2024

They will require a material change in the way many attorneys practice discovery. 1, 2024, codify procedure for depositions by remote means. Except for special proceedings, a case schedule deadline to disclose experts does not excuse a party from timely responding to expert discovery to the extent responsive information is available.

Depositions

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

AUGUST 14, 2024

defendant was sanctioned for belatedly canceling depositions that were scheduled at the discovery cutoff date. In this employment discrimination case, the defendant had noted depositions of Ms. Jones’ deposition. We notified you as soon as we learned the depositions would not be going forward.” 7, 2024)(Simms, J.),

Depositions

E-Discovery LLC

FEBRUARY 14, 2025

13, 2025), defendants waived their right to arbitration by moving to dismiss for failure to state a claim, negotiating an ESI Protocol, and engaging in discovery for 17 months. Discovery commenced after the Courts initial scheduling conference on August 15, 2023. Avis Rent a Car System LLC , 2025 WL 484588 (D.N.J.

Arbitration

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

E-Discovery LLC

OCTOBER 17, 2024

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. Albra , 2024 WL 4471672 (S.D.N.Y.

Discovery

E-Discovery LLC

DECEMBER 16, 2024

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.

Discovery

E-Discovery LLC

OCTOBER 16, 2024

When it came to discovery, it wasn’t. Tekvantage and Teknowledgies are not parties to this litigation. RFP 1: “NO SUCH DOCUMENTS EXIST” Generally, when an attorney signs a discovery response under Fed.R.Civ.P. Discovery is the Lawyer’s X-Ray; However, an MRI May Not Be Reasonable (Sep. Lain also owned Tekvantage, Inc.

Discovery

E-Discovery LLC

APRIL 10, 2025

The Sedona Conference has posted its Commentary on Discovery of Collaboration Platforms Data, Public Comment Version (Apr. 26(b)(1) states that [i]nformation within this scope of discovery need not be admissible in evidence to be discoverable, discoverable material that does not meet evidentiary standards may be of little or limited value.

Discovery

E-Discovery LLC

NOVEMBER 27, 2024

It is alleged that the documents were then used by the mother in litigation against the sole member of OLPC. They produced documents and a privilege log, but objected to a deposition. OLPC moved to compel a deposition and for additional documents or an updated privilege log. Kuendig’s deposition.

Subpoenas

Discovery Advocate

MAY 21, 2020

As courts and litigants adapt to the new normal by instituting social distancing measures through remote hearings and depositions, how we preserve, collect and produce documents should not be an afterthought. Litigation Holds: How Are Your Custodians Communicating and Saving Documents?

Discovery

E-Discovery LLC

DECEMBER 17, 2024

Plaintiffs did not disclose the identity of the consultant or the work performed; however, it came out in Dr. Singers deposition. Tesla moved to compel the whole ball of wax identity, a deposition, all documents and communications, invoices, etc. 26(a)(2) governs discovery of expert testimony. Plaintiffs offered half a loaf.

Discovery

Discovery Advocate

MAY 20, 2020

As courts and litigants adapt to the new normal by instituting social distancing measures through remote hearings and depositions, how we preserve, collect and produce documents should not be an afterthought. Litigation Holds: How Are Your Custodians Communicating and Saving Documents?

Discovery

E-Discovery LLC

AUGUST 16, 2024

In the latest iteration of In Re StubHub Refund Litigation , 2024 WL 3817068 (N.D. 13, 2024), the court began its decision of discovery issues with: “At the hearing Plaintiffs tried to walk back this [discovery] request and said it was limited to refund data, rather than a wholesale redo of non-custodial discovery.

Discovery

WA Bar News

JUNE 11, 2024

In this column, we’ll address a narrower, but more common, subset of deposition misconduct that the ABA opinion touches on: improper “coaching” during depositions and improper objections intended to impede the questioner. 10 Second, we’ll focus on depositions rather than hearings or trials. Washington RPC 4.4(a)

Depositions

E-Discovery LLC

OCTOBER 7, 2024

Fact discovery closed a day before the court’s opinion; however, it had been extended for 14 days “for the purpose of taking depositions that couldn’t be scheduled before the discovery cut-off.” Plaintiffs’ made their proposal to Meta on August 23 rd , prior to the September 30 th milestone cutting off discovery.

Discovery

E-Discovery LLC

APRIL 1, 2025

28, 2025), the court entered an order denying plaintiffs motion to compel supplemental document discovery and closing discovery. The court recited the discovery history and added: Despite the relative simplicity of this action, discovery has been anything but simple. Leadenhall Capital Partners LLP , 2025 WL 942414 (S.D.

Discovery

E-Discovery LLC

OCTOBER 22, 2024

DILATORY AND UNPERSUASIVE CHALLENGE TO DEPOSITION NOTICE “The Court need not resolve the factual skirmish over whether Washington agreed to the topics in NNI’s Rule 30(b)(6) notice to resolve the motion. The State’s newly-minted objections to the deposition topics come far too late , and are not persuasive.” Discovery Guideline 1.f).

Objections

E-Discovery LLC

AUGUST 30, 2024

However, the Court also ordered that the parties have a court reporter transcribe the session and the Court reviewed the transcript to resolve post-meeting discovery disputes. For example, the defendant had noted the deposition of Ms. Jones to take place on Monday, February 27 th , which was the day before the discovery cutoff.

Depositions

E-Discovery LLC

MAY 31, 2024

This case is, in part, a trade secret case involving alleged misappropriation of source code, so requests seeking production of source code and related data are an expected part of discovery…. The court proceeded to resolve a number of other discovery issues. 1, 2023)( untimely discovery objection was waived); cf.

Discovery

Attorney at Work

SEPTEMBER 15, 2022

As law students, few litigators imagined themselves transitioning into project management roles after passing the bar. Litigators rarely receive formal training in project management, but this does not mean they do not do project management. An Accidental Project Manager. Communication is no longer siloed between individuals.

Trial Preparation

E-Discovery LLC

APRIL 21, 2025

See, e.g., EDRM Search Guide ; The Sedona Conference Best Practices Commentary on the Use of Search and Information Retrieval Methods in E-Discovery The following are a few exemplar decisions that set the stage: In Re Seroquel Prod. Liability Antitrust Litigation , 244 F.R.D. In that case, one litigant designed its search in secret.

Discovery