How Not to Negotiate an ESI Protocol? Say it is “Mandatory”; and, Demand That Discussions be Recorded
E-Discovery LLC
MARCH 26, 2025
Pyramid Healthcare, Inc., 20, 2025), the court wrote: From the inception of this action, Counsel for the parties could not agree on the scope and methodology for ESI discovery. Second , plaintiffs service of a mandatory discovery plan was held to show a lack of cooperation. In Wilbert v. 2025 WL 873947 (W.D. Fed.R.Civ.P.
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