E-Discovery LLC

JUNE 17, 2025

“Parties should discuss how to produce the metadata and/or native files so that ESI maintains its integrity from when it is collected until when it is used in proceedings so that the parties have a method to confirm the integrity of the ESI throughout the litigation.” See The “Practical Ability” Standard for “Control” in Maryland (Dec.

Discovery

E-Discovery LLC

JANUARY 8, 2025

Plaintiff contended that, in response to plaintiffs interrogatories, Defendants improperly refer to hundreds of pages of documents, which is non-responsive, evasive, and in violation of Federal Rule of Civil Procedure 33(d). First, it must show that a review of the documents will actually reveal answers to the interrogatories.

Interrogatories

E-Discovery LLC

JUNE 20, 2024

Nor is it a positive development when that court wrote: “Things have never exactly moved along at a break-neck pace in this litigation. The main topic here is ‘contention interrogatories’…. The court explained that: “A large portion of the parties’ dispute has to do with what a contention interrogatory can ask for.

Discovery

E-Discovery LLC

AUGUST 16, 2024

In the latest iteration of In Re StubHub Refund Litigation , 2024 WL 3817068 (N.D. This is adversarial litigation, and there need to be clearly understood responsibilities. Litigation is designed to find the truth, but it is designed to find it in a particular way: adversarial testing. But that’s not true.” emphasis added].

Discovery

E-Discovery LLC

FEBRUARY 26, 2025

While Sedona correctly states that the test is whether a reasonable party in the same factual circumstances would have reasonably foreseen litigation, I have some questions about the Li Courts conclusion. Li to answer interrogatories asking if she or anyone else had deleted or destroyed any information requested in defendants discovery.

Discovery

E-Discovery LLC

MAY 27, 2025

The principal function of a scheduling order is to move the case efficiently through the litigation process by setting specific dates or time limits for anticipated litigation events to occur. Little waited ten months to answer interrogatories and did so two months after the discovery deadline. at *1, 3, 8.

Discovery

E-Discovery LLC

MAY 31, 2024

The Fiskars court explained that: The bottom line is this: Even if the court were inclined to compel production of source code and related documents, that information would be unusable in this litigation absent a dramatic upheaval of the schedule…. 14, 2024); Spoliation Motions Denied as Untimely – Another Wake-Up Call (Sep.

Discovery

Attorney at Work

AUGUST 17, 2021

We are using litigation as an example, but the same reasoning applies to transactional practices.). Example: Developing a litigation defense strategy. Examples: Administrative tasks (such as organizing files, getting docket updates and so on); routine project management tasks; data gathering on the opposing party and their attorneys.

Interrogatories

E-Discovery LLC

OCTOBER 9, 2024

One example of the court sustaining a boilerplate objection follows: Walz Interrogatory No. Defendant Walz objected to this interrogatory as overbroad and in his response, argues that it attempts to sweep the entire case. Under our rules, parties to civil litigation are given broad discovery privileges. 168, 170 n.1 154-1 at 40.

Objections

E-Discovery LLC

JUNE 24, 2024

THE MELTON FACTORS In Melton , 2024 WL 3015749, at *5, the court recognized the general rule: “[A]s a general rule, when a party fails to object timely to interrogatories, production requests, or other discovery efforts, objections thereto are waived…. The court held that one interrogatory failed to request production of the bills.

Objections

E-Discovery LLC

DECEMBER 16, 2024

Benton filed suit, Hartley Hall propounded interrogatories and document requests. Benton then responded; however, no documents were produced and Hartley Hall asserted that the interrogatory answers were incomplete or unresponsive. There are cases where litigants are being directed to support their discovery positions under oath.

Discovery

E-Discovery LLC

OCTOBER 2, 2024

Plaintiff responded that the videos were not created in anticipation of litigation and therefore they are not protected work product. It explained that “there is nothing in the record to suggest that Defendant created the requested videos in anticipation of litigation. Next , the court overruled the improper boilerplate objections.

Admissibility

E-Discovery LLC

OCTOBER 17, 2024

The court: set out the governing standard for discovery from an attorney and, denied a request to depose the attorney; but, authorized a limited interrogatory to him. The defendants, a Town and others , denied knowledge of the alleged offer. The plaintiffs wanted to develop certain property that they owned. emphasis added].

Discovery

E-Discovery LLC

JULY 6, 2024

Judge Grimm, Chuck, and Paul suggested in “Maryland Discovery Problems”: “Limitation of the inquiry to ‘material’ and ‘principal’ facts, as opposed to ‘all’ facts makes the interrogatory acceptable in form.” In Maker’s Mark Distiller, Inc. Spalding Grp., 2021 WL 2018880 at *8 (W.D.

Discovery

E-Discovery LLC

SEPTEMBER 16, 2024

“For example, in light of production of loan documents in response to Interrogatory No. Similarly, identification of details of transactions in response to Interrogatory No. 11 is unduly burdensome where the account statements have been produced.”

Discovery

CaseFox

MARCH 23, 2023

The litigation process can be lengthy and expensive, but your attorney will guide you through each step. Discovery: During the litigation process, both parties will engage in discovery, which involves exchanging information and evidence relevant to the case. This may include depositions, interrogatories, and requests for documents.

Depositions

E-Discovery LLC

SEPTEMBER 25, 2024

In the District of Maryland: “Unlike some other courts … this Court does not impose on the requesting party the burden of establishing the substantial similarity of the requested incidents and lawsuits subject at the discovery stage of the litigation. That is a very rigorous process, often necessitating expert testimony.

Discovery

SW&L Attorneys Blog

MARCH 15, 2025

Protection Of Work Product Documents created in anticipation of litigation are generally shielded from discovery because the documents contain the partys work product. Expert Witnesses Moreover, a party may inquire whether the opposing side intends to call an expert witness at trial through interrogatories submitted prior to the trial.

Discovery

WA Bar News

NOVEMBER 12, 2024

This article will explain the changes effected by the rule amendments and, with respect to CR 26, provide context considered by the Civil Litigation Rules Revision Work Group in drafting the proposed amendments to illustrate their impact. That was always the rule if CR 33 (interrogatories) and CR 34 (requests for production) were read.

Depositions

E-Discovery LLC

MARCH 8, 2025

Some litigants have refused to enter into ESI Protocols, or refused to agree to incorporate a contractual protocol into a court order, out of concern that a future failure to comply would lead to sanctions. Mistake #2: Next, Plaintiffs interrogatory responses were untimely and the U.S. In re StubHub Refund Litig., McClinton v.

Discovery

E-Discovery LLC

AUGUST 13, 2024

The Court “presided over a discovery dispute hearing related to Plaintiff’s motions to compel interrogatory requests and requests for production of documents, and related to a motion for a protective order filed by the Defendant.” 7, 2024)(Simms, J.), plaintiff, acting pro se, sued her employer, alleging discrimination.

Discovery

Lawmatics

AUGUST 8, 2023

It's a valuable tool during the case analysis phase, providing the groundwork for your litigation strategy. 5 Developing Interrogatory Questions Prompt: "You're a personal injury attorney investigating a complex multi-vehicle accident. Why It Works: This prompt helps lawyers prep and formulate precise, purposeful questions.

Legal Research

E-Discovery LLC

JUNE 25, 2024

at *5-6, passim , as well as contention interrogatories, id. See Accurate and Complete Discovery Responses Can Be Strategically Advantageous (May 13, 2024). The Norcold court addressed a number of other issues. [1] 1] __ [1] The court addressed boilerplate objections in detail, id. at *6, among other issues.

Discovery

E-Discovery LLC

SEPTEMBER 4, 2024

Discovery is the lawyer’s x-ray: “Discovery procedure serves much the same function in the field of law as the X-ray in the field of medicine and surgery; and if its use can be sufficiently extended and its methods simplified, litigation will largely cease to be a game of chance.” 691, 717 (1998)(citation omitted). “The Rodriguez v.

Discovery

E-Discovery LLC

OCTOBER 10, 2024

They “serve a vital purpose” in caseload management, which in light of “crowded dockets” is “an essential tool for handling civil litigation.” Rule 37(a)(1) requires all litigants seeking to compel discovery to certify that the movant has conferred in good faith with the party from whom they seek discovery.

Discovery

SW&L Attorneys Blog

FEBRUARY 13, 2025

Civil litigation cases involve a wide variety of topics: contracts, business disputes, construction, negligence, personal injury, contested probates, family law, and more. A general rule of thumb: if the case does not involve criminal charges or juveniles, its probably civil litigation. Contributor: Lee Grossman What Is a Deposition?

Depositions

IP Watchdog

JUNE 10, 2024

On June 6, patent owner Cellspin Soft filed a motion to compel in the Eastern District of Texas seeking a court order requiring Chinese social media company TikTok to provide additional responses to interrogatories regarding proper venue in the case.

Interrogatories

MyCase

MAY 2, 2024

Clearbrief has received renowned accolades in the legal tech industry, including the 2023 Litigation Product of the Year at Legalweek and the 2022 Legalweek Leaders in Tech Company of the Year. Their platform is ideal for trial lawyers, litigation firms, and corporate legal teams. or schedule a demo.

Discovery

E-Discovery LLC

FEBRUARY 25, 2025

wrote: It is time, once again, to issue a discovery wake-up call to the Bar in this District: the Federal Rules of Civil Procedure were amended effective December 1, 2015, and one change that affects the daily work of every litigator is to Rule 34. Forrest, 2017 WL 773694, at *1 (S.D.N.Y. accord Avila v. Target Corp., 26(d)(3)(A).

Interrogatories

Joseph, Hollander & Craft

JANUARY 24, 2025

Samantha represents professionals and their practices in Kansas and Missouri in matters involving licensure, compliance, administrative and regulatory proceedings, health and hospital law, and civil litigation involving insurance defense and business disputes.

Education

E-Discovery LLC

JANUARY 29, 2025

21, 2025), the court wrote that: Neither side distinguishes between waiver of untimely objections to interrogatories and waiver of untimely objections to RFPs, even though important differences exist in both the applicable rules of civil procedure and the case law construing them. In CT Install America, LLC v. See Fed.R.Civ.P. 468, 472-23 (D.

Interrogatories