E-Discovery LLC

JULY 26, 2025

After several extensions of time and meet-and-confers, defendants responded with only objections. The court wrote: “The Court did not grant the request for a Rule 30(b)(6) deposition but warned Defendants that that relief would be on the table if the declaration was not adequate to the task.” Plaintiffs served a document request.

Discovery

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 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 23, 2025

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…. 18, 2012)(“In reality, I struggled to fund the litigation and pay my personal bills.”… Everlast Roofing , Inc. For example, Ms.

Discovery

E-Discovery LLC

JULY 20, 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. Lively objected and wrote: “Subject to and without waiving the foregoing objections, and only after the entry of a mutually agreed upon ESI protocol, Ms.

Interrogatories

E-Discovery LLC

JULY 30, 2025

The alleged facts of the case demonstrate risks of future psychological harm and repetition of the injury against which plaintiffs are litigating. It appears from the docket that on July 21, 2025, Genesh filed an objection to the Magistrate Judge’s order on this issue. Opportunity Comm’n v. Genesh, Inc., Genesh, Inc.,

Discovery

E-Discovery LLC

JULY 22, 2025

The memorandum states that this stay of approximately two days is much less than the Fourth Circuit’s stay of 14-days that has been in effect for years, without objection, citing Standing Ord. In another, the Court extended the stay, without objection by the Government. 19-01 (4 th Cir.

Cross-Complaint

Lawmatics

MARCH 1, 2023

The rules surrounding depositions can be enough to send new lawyers into a cold sweat. Depositions are a critical tool for building a case, and as such, it is essential for attorneys of all skill levels to be well-versed in the various objections that can arise during the course of a deposition.

Depositions

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.” emphasis added).

Objections

WA Bar News

NOVEMBER 12, 2024

1 The amendments to CR 26 affect objections, supplementation, and disclosure of experts. 1, 2024, codify procedure for depositions by remote means. In response to the objection this might increase costs and introduce ambiguity, the Work Group determined most parties already ask for supplementation, so there is no net increase in work.

Depositions

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

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

AUGUST 16, 2024

In the latest iteration of In Re StubHub Refund Litigation , 2024 WL 3817068 (N.D. If StubHub provides it, and Plaintiffs don’t understand it, they should serve a 30(b)(6) deposition notice. This is adversarial litigation, and there need to be clearly understood responsibilities. But that’s not true.” emphasis added].

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

Attorney at Work

SEPTEMBER 15, 2022

Offering a legal service is, of course, quite different from developing a new disinfectant, or building a software application or a material object. As law students, few litigators imagined themselves transitioning into project management roles after passing the bar. An Accidental Project Manager. A Powerful Project Management Panacea?

Trial Preparation

E-Discovery LLC

MAY 31, 2024

The Fiskars court explained that: The bottom line is this: Even if the court were inclined to compel production of source code and related documents, that information would be unusable in this litigation absent a dramatic upheaval of the schedule…. 1, 2023)( untimely discovery objection was waived); cf.

Discovery

E-Discovery LLC

OCTOBER 17, 2024

They also sought the former attorney’s deposition regarding the alleged offer. When it came to the request for a deposition , the court wrote: Lastly, Plaintiffs request a deposition of former Town Attorney Nugent in connection with his role in making the alleged quid pro quo as outlined in Plaintiffs’ motion papers.

Discovery

E-Discovery LLC

DECEMBER 19, 2024

In In re Outpatient Medical Center Employee Antitrust Litigation , 2024 WL 4679083 (N.D. Plaintiffs later noted the deposition of a non-party, Dr. Fanning on March 29, 2024. Objections were due by July 10 th. Fanning and well before the deposition. Subsection (d) provides: (d) Controlling Effect of a Court Order.

Depositions

E-Discovery LLC

MARCH 8, 2025

Some litigants have refused to enter into ESI Protocols, or refused to agree to incorporate a contractual protocol into a court order, out of concern that a future failure to comply would lead to sanctions. The court wrote that it then adopted Defendants protocol [as an order] and no objection to that order was filed. Emphasis added].

Discovery

The Cloud Court Blog

OCTOBER 26, 2022

Over the years I’ve attended a lot of depositions. When the deposition is over, the people that were in the room often have a sort of inexplicable, Venn-type diagram of disparate recollections about what actually happened. But now, as my team has continued to study depositions, I've come to suspect that something else is at play here.

Depositions

The Cloud Court Blog

SEPTEMBER 28, 2022

I am obsessed with depositions and, in particular, their importance to the outcome of cases. That obsession extends to deposition data as well as to the psychology of the players involved: the attorneys taking and defending depositions; the witnesses being deposed; as well as the court reporters. Why on earth would we do this?

Litigation

E-Discovery LLC

DECEMBER 16, 2024

Etame did not appear for his deposition on March 10, 2022. Nguhs motions, but held the sanctions motion in abeyance, and ordered Mr. Etame to appear for deposition. After the parties discussed scheduling, Mr. Etame failed to appear for deposition. As a result, Ms. Nguh filed a motion for sanctions for his failure to appear.

Discovery

E-Discovery LLC

APRIL 10, 2025

The potential downside of unitization by time period or number of messages is that it can artificially break up continuing conversations into separate documents, requiring the parties to manually reassociate them for use in the litigation. The adverse party may do so over a hearsay objection. emphasis added]. Rodriguez v. Fed.R.Evid.

Discovery

E-Discovery LLC

AUGUST 13, 2024

Next, the undersigned specifically directed the parties to identify a timetable for completion of all discovery, including taking any depositions. ( Regarding depositions, the undersigned cautioned Plaintiff that if she wanted to take any depositions, she was to communicate with the Defendant’s counsel about the same. (

Discovery

E-Discovery LLC

AUGUST 31, 2024

These videos were admitted into evidence without objection and were contained in about 30 video exhibits. Over objection, Lieutenant McDonald testified that he focused on one of the suspects who wore distinctive attire. The court admitted the composite video over objection. before the shooting; on Pleasant Street at 12:17 a.m.

Admissibility

E-Discovery LLC

AUGUST 21, 2024

See Felder Part 2 of 4: Defendant Sanctioned for Late Cancellation of Depositions. Giant objected….”); Steamfitters Loc. By then, the video had been overwritten. This is the third of a four-part blog on Felder , an employment discrimination case. at *7 (emphasis added). WHEN IS THE DUTY TO PRESERVE TRIGGERED?

Evidence

The Cloud Court Blog

FEBRUARY 24, 2023

It began as a series of reports combined into a dashboard that provided insights about deposition transcripts. Now, Gibson is more than a tool; it’s a partner for any litigator that augments their ability to devise deposition strategies and tactics and improve outcomes. (We Gibson drives better litigation results.

Depositions

E-Discovery LLC

JANUARY 8, 2025

Reliance on Rule 33(d) is appropriate when the interrogatory requests objective facts that are obvious from the specified documents, but is generally inappropriate when the interrogatory asks a party to state its contentions or to state facts supporting its allegations.

Interrogatories

SW&L Attorneys Blog

MARCH 15, 2025

A failure to provide the requested information without valid objections may result in a motion to compel, a procedural mechanism through which a party seeks judicial intervention to enforce compliance. The opposing party may object to discovery requests by asserting that the information sought is cumulative, duplicative, or unduly burdensome.

Discovery

Optima Juris

JUNE 1, 2025

Todays litigators must navigate an ever-growing mountain of case data, documents, and transcripts. One deposition transcript can easily stretch beyond 200 pages. Based on our experience supporting firms across remote depositions and arbitrations, here’s what we’ve seen working on the ground.

Depositions

E-Discovery LLC

OCTOBER 6, 2024

The decision reinforces the need for carefully-designed, proactive, and comprehensive information governance and litigation hold procedures. It noted that Mr. Shapiro even testified during depositions that he could not identify a single email that anyone read. Hyperheal Hyperbarics should at least raise a yellow flag for employers.

Evidence

E-Discovery LLC

MAY 14, 2025

Upon reviewing Plaintiffs production, Defendants objected and claimed that Plaintiffs unilateral redaction of text messages within a same-day text chain was improper. Plaintiffs objected and, alternatively, sought a protective order. Litigants, and courts, are still in the process of figuring out how to answer these questions.

Discovery

SW&L Attorneys Blog

NOVEMBER 8, 2024

Stashing Physical Cash or Valuables: Assets like cash, jewelry, or collectibles are sometimes hidden in safety deposit boxes, with friends or family, or in obscure locations to avoid being accounted for. This reduces income on record, lowering obligations for spousal support or shared property distribution. In Bollenbach v.

Finance and Banking

The Cloud Court Blog

AUGUST 17, 2022

Ask them to change only one thing about how they conduct their litigation practices. How do you overcome these aphoristic objections? Suppose you have a matter where you’re noticed for several depositions. Within a few months, every litigation attorney is having the app ride shotgun in every deposition – taking and defending.

Depositions

WA Bar News

NOVEMBER 12, 2024

Humphries stipulated to suspension for: 1) failing to reasonably consult with clients about the means by which the clients’ objectives were to be accomplished; 2) providing legal services to clients, without their informed consent, confirmed in writing, to conflicts of interest created by Respondent’s representation. Suspended Leslie R.

Depositions

WA Bar News

APRIL 14, 2025

Their role varies with any given litigation. In another, the witness may be a former employee who can provide the institutional memory of why a company involved in litigation did or did not take particular action in the past. Fucile Fact witnesses can make a critical difference in a case. b) in Washington for context. 2d 502, 29 P.3d

Witnesses

The Cloud Court Blog

FEBRUARY 9, 2022

Shifting a culture toward innovation means de-emphasizing checklists and focusing only on the most important handful of objectives. If you or your litigation team have an initiative to look for ways to improve deposition performance, accelerate resolutions, or achieve better outcomes, contact us and request a custom demo.

Depositions