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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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Court’s Use of a Special Master to Assist EEOC in Obtaining Discovery from Defendant

E-Discovery LLC

18, 2025) (“ Genesh IV ”), after several rulings adverse to Genesh, the court appointed a Special Master to facilitate the plaintiff EEOC’s discovery from the defendant , Genesh, Inc. A substantial amount of discovery took place before Ms. Genesh, Inc., 24-2445-DDC-ADM (D. 2000e-5(f)(1); however, Genesh asserted that Ms. Genesh, Inc.,

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The Quiet Force Behind Successful Outcomes: Pretrial Motions

Joseph, Hollander & Craft

Motion in Limine: While a motion to suppress is typically based on constitutional objections, a motion in limine – which also asks a court to limit or exclude certain evidence – is based on evidentiary concerns. A related motion is one for discovery sanctions. Effective use of limine motions can shape the trial.

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When Can a Court Deviate from the Child Support Guidelines?

Joseph, Hollander & Craft

We can also use the discovery process to ask key questions and obtain documents. Mediation can be an effective tool for resolving the case with minimal court involvement. As with other cases involving child support deviation, our objective is to get a full view of the parents’ finances, the child’s needs, and related matters.

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Court Appointed ESI Discovery Supervisor for ESI Protocol

E-Discovery LLC

District Court for the District of Maryland as the “ESI Discovery Supervisor” in a complex commercial case, with the task of “oversee[ing] the negotiation of an ESI protocol.” Then, the process led to the filing of a “Stipulated ESI Protocol and Discovery Plan.” Discovery Plan” (Jan. Mayflower Textile Servs. Berman and The Hon.

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Discretionary Stay of Discovery Pending Decision on Dispositive Motion

E-Discovery LLC

Defendants moved to stay all discovery deadlines pending a resolution of their motion to compel arbitration and for a stay pending arbitration. The motion to stay discovery was granted. The Court wrote that: It is axiomatic that district courts enjoy substantial discretion in managing discovery. 10, 2025)(Austin, J.),

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My Most Interesting Blogs From 2024

E-Discovery LLC

Discovery Plan The ESI Protocol: Your Word is Your Bond Or, Is It? Boilerplate Objections Are Generally Condemned; Except When Theyre Not Citing the Correct Subsection of Fed.R.Evid. Boilerplate Objections Are Generally Condemned; Except When Theyre Not Citing the Correct Subsection of Fed.R.Evid.