“Diligent Search,” But No Responsive Data, is Insufficient Response
E-Discovery LLC
JUNE 10, 2025
Interestingly, this is the same type of evidence produced two decades ago in the seminal Zubulake case. The Mia Aesthetics court cited precedent that a defendant must make a reasonable effort, assisted by a vendor, to recover or restore relevant and responsive ESI that was lost or deleted. Zubulake (Aug. 18, 2012). [1]
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