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. The Wilbert court entered an order that Attorney XXXX show cause why sanctions should not be imposed. In Wilbert v. 2025 WL 873947 (W.D.
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