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CONSIDER A TRIAL CHECKLIST

Plaintiff Trial Lawyer Tips

Opening statement, witness examination & summation Depositions  Review all depositions & index for access at trial  Create summary of relevant testimony with index to access at trial  Decide how to use at trial. Supplement if needed. Index & make summary of relevant information for use at trial.

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Self-Collection, Discovery About Discovery, and Curative Sanctions

E-Discovery LLC

37(e)(1) sanctions, the EEOC sought copies of litigation hold notices, dates and the names of recipients of those notices, as well as further descriptions; appointment of a forensic examiner to determine when the ESI went missing; and, a Rule 30(b)(6) deposition on the missing ESI at defendant’s expense. As Fed.R.Civ.P. May 26, 2011).

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Town Sanctioned for Prejudicial Breaches of Duty to Preserve in Alleged Sexual Assault Case; Court Also Addresses Use of Personal Email by Council Members

E-Discovery LLC

Doe complained of alleged piecemeal document production and, after deposition, “grew concerned” that relevant documents had not been produced. see generally Burden of Proof: Sanctions for Intentional Deletion of Text Messages (Jul. 21, 2021); Burden of Proof of Spoliation (Dec. She sued officers and the Town.