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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

The Court stands ready and willing to mediate such legitimate disputes. 22, 2023); Court Uses an Informal Discovery Procedure to Hold That Untimely Objections Were Waived, and Answers to Interrogatories Defectively Referred to Deposition (Nov. 15, 2025). [2] 2] Orders to meet, confer, and, cooperate are not uncommon. 15, 2025). [2]

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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 favorable ruling can so change the scope of the case as to require dismissal of criminal charges or return of property.

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When Can a Court Deviate from the Child Support Guidelines?

Joseph, Hollander & Craft

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. We can also use the discovery process to ask key questions and obtain documents.

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Court Appointed ESI Discovery Supervisor for ESI Protocol

E-Discovery LLC

With the consent of two sophisticated and cooperative groups of litigants, I conducted the process much like a mediation, beginning with ex parte communications with both sides. I have long favored Mediation of ESI Disputes ; JAMS: “Mediating E-Discovery Can Save Time and Money”. Berman, et al., State Bar Ass’n.

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My Most Interesting Blogs From 2024

E-Discovery LLC

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. Mediation of Discovery Disputes by Courts Law Clerk?

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Orban’s Peace Gambit: Diplomacy and Conflict in the Evolving Russia-Ukraine War

Complex Discovery

We cover recent diplomatic moves, including Hungarian Prime Minister Orban’s mediation attempts, alongside military developments such as Russian advances and Ukrainian counterstrikes. Orban seems to be positioning himself as a potential mediator, pushing for a shift in European focus from military support to peace talks.

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Discretionary Stay of Discovery Pending Decision on Dispositive Motion

E-Discovery LLC

On the telephone conference, defense counsel represented that a litigation hold has been in place since summer 2023, a few months after this dispute arose and the parties agreed to pre-litigation mediation.