Based on the ESI Protocol, the Limiting “Apex Deposition” Doctrine Applied to Objections to the Designation of a Document Custodian
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).
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