Case Management, Counterclaim and Objections

Should Discovery be Stayed Pending Ruling on Dispositive Motion?

E-Discovery LLC

APRIL 3, 2025

Defendant argues that discovery in this case should be stayed pending the resolution of its motion to dismiss, that the requested discovery contains proprietary and confidential information, and stands on various of objections. It also considers the complexity of the action and whether there are counterclaims or cross-claims.

Discovery

Discovery Cross-Complaint Counterclaim Litigation

Proportionality and Labeling ESI Productions

Joshua Gilliland

JANUARY 30, 2016

The Plaintiff rightly objected to these requests, but made only improper boilerplate objections. The new Rule 34(b)(2)(B)-(C) requires parties to object with “specificity” and “an objection must state whether any responsive materials are being withheld on the basis of the objection.”

Objections

Objections Discovery Counterclaim Case Management

Trial Strategy Today

Should Discovery be Stayed Pending Ruling on Dispositive Motion?

Proportionality and Labeling ESI Productions

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