E-Discovery LLC

JULY 14, 2025

But some experts have defended the doctrine by warning about the discovery abuses that Meta alleges are at play here. And, Meta asserts that, because discovery orders are not generally appealable, absent mandamus, the scope of the doctrine will not be addressed at the appellate level. 1, 2025).

Depositions

E-Discovery LLC

JULY 29, 2025

E-Discovery LLC (Jul. It is axiomatic that discovery responses themselves have significant evidentiary value as they constitute party admissions. But without a clear connection between the discovery requests and the corresponding responses, the discovery responses cannot be deemed reliable.

Discovery

E-Discovery LLC

JUNE 19, 2025

Fourth , Plaintiff demanded that defendant provide the date when defendant anticipated “imminent” litigation, the exemption standard under a Florida public records statute. After all, one of the recipients is Defendant’s litigation counsel in this case. Commentary-on-Privilege-Logs-May-2024.pdf The email may very well be privileged.

Discovery

E-Discovery LLC

JUNE 17, 2025

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. 2] For more on the written agreement, an “ESI Protocol” or “Discovery Plan,” see “ESI Protocol” v. Discovery Plan” (Jan. Emphasis added].

Discovery

E-Discovery LLC

JUNE 30, 2025

Their motion to compel was granted over relevance and other objections. The court wrote: “Thus, Defendants must produce documents sufficient to show their efforts to settle the ExWorks litigation….” Gensler, “Bull’s-Eye View of Cooperation in Discovery,” 10 Sedona Conf. Emphasis added]. Ardagh Metal Packaging USA Corp.

Discovery

E-Discovery LLC

JULY 16, 2025

“[W]hile I find defendants negligently failed to preserve video footage, I find they are not guilty of spoliation because such footage is not responsive to plaintiff’s discovery requests or relevant.” It is triggered when a potential party has “some notice that the evidence is potentially relevant to… reasonably foreseeable litigation.”

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. After several extensions of time and meet-and-confers, defendants responded with only objections.

Discovery

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. Thus, this Court has deemed such ostensible objections waived or [has] declined to consider them as objections.”

Interrogatories

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., Once that was done, the requesting party could identify three more, “subject to limited objections.” 2025 WL 1755650, at *1 (N.D. June 25, 2025).

Objections

E-Discovery LLC

JULY 6, 2025

That is especially so here, where tolling is a central issue in this case and where the Cácereses have expressly cited communications with their attorneys in sworn discovery responses about how they investigated and ultimately discovered their potential claims. The court also overruled an objection to the deposition of an SGR attorney.

Interrogatories

E-Discovery LLC

JUNE 16, 2025

That duty arises “when a party reasonably should know that the evidence may be relevant to anticipated litigation.” Id. A prudent person acting under like circumstances would have saved and downloaded the Drive Cam footage from the MetroAccess van in anticipation of future litigation. at *3 (quotations and citations omitted).

Expert Testimony

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

Planet Depos

JUNE 17, 2025

Deposition (law) A deposition is the act of taking sworn testimony whereby litigants obtain information from each other in preparation for trial. Listen to any objection by your lawyer but understand your lawyer cannot use objections to “coach” you how to answer the question. What is a deposition?

Depositions

E-Discovery LLC

JULY 2, 2025

Lively challenged the Wayfarer Parties’ standing to assert privacy interests of non-parties…. ‘[T]he Wayfarer Parties have not demonstrated standing to object to the Subpoena requests seeking the phone records of non-parties…. 19, 2024); What “Expenses” Can a Non-Party Recover for Complying With a Discovery Subpoena? 8, 2025)(“Ms.

Subpoenas

Complex Discovery

JULY 3, 2025

Core offerings include Global Advisory, Data Discovery Intelligence, HaystackID Core® Platform, and AI-enhanced Global Managed Review powered by its proprietary platform, ReviewRight®. Known for his forward-thinking approach, Jim encourages legal professionals to embrace AI as a means to future-proof their careers.

Education

E-Discovery LLC

JUNE 10, 2025

May 30, 2025), the EEOC prevailed on several discovery disputes. It prevailed because its attorneys did their homework and supported their litigation position with facts. The agency moved to compel discovery responses. The EEOC also asked the court to order Mia Aesthetics to retain an e-discovery vendor. Zubulake (Aug.

Discovery

Complex Discovery

JULY 17, 2025

For eDiscovery experts, this translates into more jurisdictional layers and greater variation in data environments, especially when managing cross-national litigation or compliance mandates. Second, indicators tied to intellectual assets and SME collaboration reflect how information flows are structured and protected.

Government and Public Sector

Joseph, Hollander & Craft

JULY 23, 2025

Civil, family, and criminal courts allow for these pretrial motions, which can shape future proceedings and therefore the trajectory of litigation. A related motion is one for discovery sanctions. What Are Pretrial Motions? A court can dismiss civil claims as well as criminal charges.

Pretrial Motions

Complex Discovery

JULY 21, 2025

Whether conducting risk assessments, validating vendor claims, or ensuring defensibility in litigation, recognizing the type of bias at play is foundational to effective governance. Discriminatory bias is especially dangerous because it can mask itself behind the appearance of objectivity and automation.

Technology

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. E-Discovery LLC (Jul. 19-01 (4 th Cir. Merrill , 332 U.S.

Cross-Complaint

Complex Discovery

JULY 27, 2025

Industry Newsletter Five Great Reads on Cyber, Data, and Legal Discovery for July 2025 ComplexDiscovery Staff Welcome to the July 2025 issue of the ComplexDiscovery OÜ newsletter , a curated narrative highlighting key developments across cybersecurity, legal discovery, data governance, and the accelerating realm of artificial intelligence.

Discovery

Complex Discovery

JULY 19, 2025

This unique background positions ComplexDiscovery to provide valuable insights for conflict-related investigations and litigation, where understanding the interplay of technology, data, and geopolitical factors is crucial. strategic objectives. ISW is a non-partisan, non-profit, public policy research organization.

Objections

Complex Discovery

JULY 24, 2025

Simultaneously, the plan calls for updating procurement policies to contract only with frontier large language model developers whose systems are demonstrably objective and free from what the plan refers to as “top-down ideological bias.” This move could reshape evidentiary standards in digital litigation and compliance.

Technology

Percipient

JULY 1, 2025

When law enforcement serves a warrant or a civil litigant serves a subpoena seeking your company’s electronically stored information, is your organization prepared to properly respond? For instance, the government is often entitled to more information than a private civil litigant. To learn more, schedule a discovery call today.

Subpoenas

Complex Discovery

JUNE 8, 2025

This unique background positions ComplexDiscovery to provide valuable insights for conflict-related investigations and litigation, where understanding the interplay of technology, data, and geopolitical factors is crucial. strategic objectives. ISW is a non-partisan, non-profit, public policy research organization.

Objections

E-Discovery LLC

JUNE 28, 2025

. __, 2025 WL 1540660 (May 30, 2025), the defendant City claimed unfair surprise when plaintiff sought to introduce at trial photographs that the City had taken, but which plaintiff had not disclosed in discovery. In discovery, defendant asked for all photos, and any documents on which plaintiff intended to rely on at trial.

Discovery

Complex Discovery

JULY 26, 2025

This unique background positions ComplexDiscovery to provide valuable insights for conflict-related investigations and litigation, where understanding the interplay of technology, data, and geopolitical factors is crucial. strategic objectives. ISW is a non-partisan, non-profit, public policy research organization.

Government and Public Sector

E-Discovery LLC

JULY 28, 2025

The government argues that Plaintiffs’ motion should be denied because Plaintiffs “made no attempt to comply with the Touhy process.” … The government contends that “[f]ailure to engage in the Touhy process renders a discovery request unenforceable.” The court wrote: The Federal Housekeeping Statute, 8 U.S.C. § Section 5.41(a)

Discovery

E-Discovery LLC

AUGUST 1, 2025

But the dissent overlooks that both parties, in their testimony, testified about and confirmed the cover letter’s contents verbatim, and without objection. So even if the substance of the cover letter constituted hearsay, any objection on that basis was waived, as its contents were in evidence and undisputed.

Discovery

E-Discovery LLC

APRIL 22, 2025

15, 2025), the court ordered discovery of litigation hold notices. In my opinion, and while I agree with the result, the legal issues governing the discovery of litigation hold notices and implementation need clarity and national uniformity. In Another Approach to Drafting and Discovery of Litigation Hold Notices (Feb.

Discovery

E-Discovery LLC

SEPTEMBER 16, 2024

9, 2024), provides a succinct summary of the scope of discovery under the December 2015 amendments to the Federal Rules of Civil Procedure. It – surprisingly – sustained boilerplate objections. Information within this scope of discovery need not be admissible in evidence to be discoverable.” The case involved a loan gone south.

Discovery

E-Discovery LLC

MAY 17, 2025

When they were unable to do so, they submitted competing suggestions, and, the United States Magistrate Judge then issued a Protocol and Order Governing Discovery (the ESI Order) establishing such a protocol. The City Defendants objected to the ESI Order. The objection was overruled. In Rayome v. Fed.R.Civ.P.

Objections

E-Discovery LLC

AUGUST 3, 2024

July 17, 2024), the court held that no privilege log was required until scope of discovery objections were resolved. The general rule is that a privilege log is due at the time discovery responses are filed. 24, 2024); Court Excused Party From Waiver by Failure to Provide Specific Objections (Aug. KPC Healthcare, Inc.,

Objections

E-Discovery LLC

FEBRUARY 21, 2025

By definition, a litigation hold notice is a communication from an attorney to a client regarding the duty to preserve potentially responsive information. [1] 7, 2025), the court held that litigation hold notices were privileged. Defendants objected. DISCOVERY OF LITIGATION HOLD NOTICES HAS LONG BEEN AN ISSUE.

Discovery

E-Discovery LLC

NOVEMBER 1, 2024

Despite several extensions of time, the defendant essentially told the court that it had been too busy to respond to discovery. Plaintiff Orlando sought discovery from defendant HKS. All objections to the discovery at issue, other than privilege, have been waived by the failure to timely respond to the discovery.”

Objections

E-Discovery LLC

OCTOBER 9, 2024

27, 2024), “boilerplate” objections were sustained on the specific facts presented. BOILERPLATE OBJECTIONS HAVE GENERALLY BEEN CONDEMNED Boilerplate objections have generally been condemned. See General Objections, Dracula, and “Whac a Mole” (Apr. In Jacobs v. The Journal Publishing Co., 2024 WL 4333199 (D. 168, 170 n.1

Objections

E-Discovery LLC

OCTOBER 15, 2024

July 22, 2024), the Court addressed the type of objections that a subpoenaed non-party may make. Both the husband and wife sought discovery from TST. TST objected on, inter alia , lack of relevance and overbreadth. With no other factual predicate to support the objection, it was overruled. In Trusted Sci. &

Subpoenas