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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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Discovery 101 – Court Sets Out Ground Rules to Resolve Discovery Dispute

E-Discovery LLC

clearly sets out a series of rules governing discovery disputes. At a status conference, each party asserted that the other had not adequately responded to discovery requests. 5] “The rules also require objections to interrogatories and requests for production of documents to be made with specificity.” [6] 21, 2025)(Stafford, J.),

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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. In Connor , privilege log entries were inconsistent with a litigant’s testimony about when termination was first discussed.

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Requests for Documents “Sufficient to Show,” Instead of “Any and All” Documents

E-Discovery LLC

“Sufficient to show” requests are an example of what is called the “bull’s eye view” of focused discovery requests. Gensler, “Bull’s-Eye View of Cooperation in Discovery,” 10 Sedona Conf. 363 (2009); New Sedona Primer Implements the “Bull’s Eye View” of Discovery Requests (Dec. However, “sufficient to show” is not a magic term.

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All Metadata is Not Equal – Court Orders Narrower Request

E-Discovery LLC

the Court applied its Principles for the Discovery of Electronically Stored Information in Civil Cases (“ESI Principles”) to order that a discovering party narrow its request for metadata. The Court also found several interrogatory answers to be insufficient and others sufficient. Discovery Plan” (Jan. Discovery Plan” (Jan.

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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. The court wrote: Although Lively’s damages may depend largely on expert discovery, this does not relieve her of the obligation to comply with Rule 26. [C]ourts Mayflower Textile Servs.