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
Once that was done, the requesting party could identify three more, “subject to limited objections.” 45 subpoena duces tecum could not have been served on the non-party document custodian and avoided the designation issue. The ESI Protocol required that the responding party designate ten document custodians. 2025 WL 176001, at n.
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