E-Discovery LLC

JULY 18, 2025

A protective order barring post-settlement use by plaintiffs’ counsel of defendant’s discovery responses in other litigation was vacated in Cordero v. The Ninth Circuit wrote: It is “well-established” in our case law that discovery is “presumptively public.” Stemilt AG Services, LLC, __ F. 4 th __, 2025 WL 1902292 (9 th Cir.

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 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.

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 Plan” (Jan.

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 19, 2025

Cooperation, proportionality, and transparency are always paramount in electronic discovery, including privilege logging. Negotiation of a discovery plan or ESI Protocol [1] addressing privilege logging is the best approach. See No Privilege Log is Necessary in Limited Circumstances When Discovery Requests Are Overbroad (Apr.

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. 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. 8, 2025). 354, 359 (D.

Interrogatories

E-Discovery LLC

JUNE 30, 2025

Their motion to compel was granted over relevance and other objections. Similarly, RFP 26 was drafted as a request for documents “sufficient to show” another factual issue. “Sufficient to show” requests are an example of what is called the “bull’s eye view” of focused discovery requests. Emphasis added]. June 10, 2025); E.D.Q.C.

Discovery

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

JULY 1, 2025

Once that was done, the requesting party could identify three more, “subject to limited objections.” The ESI Protocol required that the responding party designate ten document custodians. 2025 WL 176001, at n. Plaintiffs prevailed. 2025 WL 176001, at *1 (cleaned up; citations and quotations omitted). emphasis added).

Objections

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.” In other words, the trigger analysis is objective, not subjective. The temporal scope of the discovery request was significant.

Discovery

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

Planet Depos

JUNE 17, 2025

The chief value of a deposition, as with any discovery proceeding, is to give all litigant parties in a contested case a fair preview of the evidence so that a “level playing field” is achieved and surprise (traditionally regarded as an unfair tactic) is avoided at time of trial. Be sure you understand the question.

Depositions

Steno

JANUARY 6, 2025

He needed an objective way to evaluate his performance and identify potential blind spots in his questioning strategies. 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.

Depositions

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. The agency moved to compel discovery responses. The EEOC also asked the court to order Mia Aesthetics to retain an e-discovery vendor. Book Review: “Zubulake’s e-Discovery: The Untold Story of My Search for Justice,” by Ms. Webb sent to management; 3) Ms.

Discovery

E-Discovery LLC

JUNE 16, 2025

Moore claimed the missing video was objective evidence that “could corroborate or refute” the parties’ testimony, she offered no particularized evidence that the footage would have supported her claim. This blog was initially posted on Electronic Discovery Reference Model. Applying these principles, the Moore Court held that Ms.

Expert Testimony

Complex Discovery

JULY 17, 2025

Its layered methodology offers policymakers a way to link innovation performance with strategic objectives: green transition, digital transformation, economic security, and social cohesion. It feeds into the Competitiveness Compass, the EU Startup and Scaleup Strategy, and will serve as a foundation for the forthcoming Innovation Act.

Government and Public Sector

Complex Discovery

JULY 10, 2025

” As organizations face economic uncertainties and escalating cybersecurity threats, it has become increasingly essential to anchor technology investments in objectives that steer growth and competitive advantage.

Technology

Complex Discovery

JULY 27, 2025

Our editorial focus begins with objective reporting of industry developments, grounded in primary sources, expert insight, and meaningful context. These are the moments where strategic thought takes root, where writing becomes refinement, and where the signal rises above the noise.

Energy and Utilities

Joseph, Hollander & Craft

JULY 23, 2025

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.

Pretrial Motions

Complex Discovery

JULY 21, 2025

Discriminatory bias is especially dangerous because it can mask itself behind the appearance of objectivity and automation. For instance, an algorithm trained on historical hiring data may continue to disadvantage certain racial or gender groups even if the inputs appear neutral.

Technology

Percipient

JUNE 20, 2025

Schedule a discovery call with Percipient and take control of your contract process today. Always establish clear objectives before you begin. No more guesswork. No more long review cycles. Ready to stop juggling edits and chasing updates? Let Percipient help you manage contract redlining the smart way. How to properly redline?

Legal Services

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

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 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.” The message is clear: government should accelerate, not regulate, the future.

Technology

Complex Discovery

JULY 19, 2025

This lays the analytical foundation for understanding the reasons for particular developments and fulfilling their assigned research objectives. strategic objectives. They must also understand the population demographics, physical terrain, politics, and history of that area. Learn more, get involved, and contribute today.

Objections

Percipient

JULY 1, 2025

Challenge the Request if Necessary: You may have grounds to object to a subpoena or challenge the request (e.g., To learn more, schedule a discovery call today. if it’s overly broad or lacks proper legal basis). If you are interested in securing outside help responding to subpoenas, let us know.

Subpoenas

Complex Discovery

JUNE 8, 2025

While this policy shift represents a notable change in Washington’s posture, the ISW assesses that economic pressure alone is unlikely to coerce Russian President Vladimir Putin to negotiate or abandon his objectives. 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 aligns with a broader Russian objective to envelop Kupyansk and force a Ukrainian fallback across the Kupyanka River. Each course underscores Russia’s dual objectives—incremental territorial gains and optimized force allocation across its priority sectors. strategic objectives.

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. § Emphasis added].

Discovery

Joseph, Hollander & Craft

JULY 10, 2025

We can also use the discovery process to ask key questions and obtain documents. 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. Settlement through mediation may be possible, avoiding the time and hassle of court hearings.

Finance and Banking

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

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

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.

Objections