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

E-Discovery LLC

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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Privilege Objections Denied Without Prejudice

E-Discovery LLC

non-party TEDCO’s blanket privilege and work product objections to a subpoena were denied; however, it lived to fight another day because the denial was without prejudice to file supported objections after a “meet and confer.” Specific objections are required. And, ImpactHR responded without objection. emphasis added].

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“Boilerplate” Objections Are Generally Condemned; Except When They’re Not

E-Discovery LLC

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. at 190, 192.

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Litigants Can’t Agree; Judge Entered an ESI Protocol;  Party Objected to It; Objections Overruled

E-Discovery LLC

The City Defendants objected to the ESI Order. The objection was overruled. As noted, after the court ruled, the City Defendants objected to the Magistrate Judges decision. The Hall court addressed each argument and overruled all of the City Defendants objections. In Rayome v. ABT Electronics , 2024 WL 1435098 (N.D.

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Prep with Purpose: How to Build Better Trial Binders

Speaker: Joe Stephens, J.D., Attorney and Law Professor

Learning Objectives: Strategic Organization 📊 Learn the essential sections every trial notebook needs and how to structure them for maximum clarity and accessibility during high-pressure moments. Attorney and law professor, Joe Stephens, J.D.,

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What Objections May Be Raised to a Subpoena by a Non-Party?

E-Discovery LLC

July 22, 2024), the Court addressed the type of objections that a subpoenaed non-party may make. TST objected on, inter alia , lack of relevance and overbreadth. The trial court rejected TST’s relevance objection, stating: “[A] third party doesn’t really, in my estimation, have standing to argue about relevance and overbreadth.

Subpoenas 130
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Party’s Motion to Quash Subpoena Denied for Lack of Standing

E-Discovery LLC

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…. 27, 2024); Who Can Object to a Subpoena? “It Ends With Us” (Apr. 8, 2025)(“Ms. 24, 2022).

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Deposition Prep Like a Pro: Insights from a Paralegal's Playbook

Speaker: Kaitlyn "The Persnickety Paralegal" Story

Key Learning Objectives: Control the Cadence of the Case 🕒 Learn how to effectively manage and control the flow of your case by ensuring that the timing of the deposition aligns with the specific needs of each case and the preferences of the attorney.

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No Objections: Better Case Management with AI for Paralegals

Speaker: Joe Stephens, J.D., Attorney and Law Professor

Key Learning Objectives: Understanding Every Case Phase 🔑 Explore the key phases every case goes through, and the vital paralegal tasks at each stage that can make or break a case. Attorney and law professor Joe Stephens, J.D.,

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Trial Prep: What Attorneys Really Want (And How to Deliver It)

Speaker: Joe Stephens, J.D., Attorney and Law Professor

Key Learning Objectives: Organization That Makes Sense 🎯 Learn how to structure and organize case materials in ways that align with how attorneys actually work and think. Attorney and law professor, Joe Stephens, J.D.,