E-Discovery LLC

DECEMBER 16, 2024

26, 2024)(unreported), dismissals for discovery violations were affirmed. Nguh, one owner, propounded discovery on Mr. Etame, the opposing owner. The Appellate Court wrote: Mr. Etame failed to respond to discovery, and on March 3, 2022, Ms. Etame did not appear for his deposition on March 10, 2022. As a result, Ms.

Discovery 130

Discovery Interrogatories Affidavits Pleadings 130

E-Discovery LLC

SEPTEMBER 18, 2024

the Court addressed two important discovery issues. Second , where a Rule 30(b)(6) deponent reviewed an allegedly privileged document in deposition preparation in order to refresh her memory, the privilege, if any, was waived. In Faulkenberry v. Austin , 2024 WL 4056761 (D. 5, 2024)(Coulson, J.), at *2 (emphasis added).

Depositions 130

Depositions Privileged Communication Witnesses Discovery 130

E-Discovery LLC

DECEMBER 17, 2024

Plaintiffs did not disclose the identity of the consultant or the work performed; however, it came out in Dr. Singers deposition. Tesla moved to compel the whole ball of wax identity, a deposition, all documents and communications, invoices, etc. 26(a)(2) governs discovery of expert testimony. Plaintiffs offered half a loaf.

Discovery 130

Discovery Depositions Trial Preparation Expert Testimony 130

E-Discovery LLC

OCTOBER 16, 2024

When it came to discovery, it wasn’t. RFP 1: “NO SUCH DOCUMENTS EXIST” Generally, when an attorney signs a discovery response under Fed.R.Civ.P. Discovery is the Lawyer’s X-Ray; However, an MRI May Not Be Reasonable (Sep. Kranz & Associates Holdings, LLC v. Lain , 2024 WL 4476655 (N.D. Lain also owned Tekvantage, Inc.

Discovery 130

Discovery Subpoenas Depositions Evidence 130

E-Discovery LLC

NOVEMBER 27, 2024

They produced documents and a privilege log, but objected to a deposition. OLPC moved to compel a deposition and for additional documents or an updated privilege log. That motion was granted in part, with the court ordering the law firm to produce documents or an adequate privilege log and compelling the deposition.

Subpoenas 130

Subpoenas Discovery Depositions Objections 130

WA Bar News

JUNE 11, 2024

In this column, we’ll address a narrower, but more common, subset of deposition misconduct that the ABA opinion touches on: improper “coaching” during depositions and improper objections intended to impede the questioner. 10 Second, we’ll focus on depositions rather than hearings or trials. Washington RPC 4.4(a)

Depositions 98

Depositions Witnesses Objections Discovery 98

Discovery Advocate

MAY 21, 2020

As courts and litigants adapt to the new normal by instituting social distancing measures through remote hearings and depositions, how we preserve, collect and produce documents should not be an afterthought. Postpone that discovery until such a time it is safe and permissible to collect the potentially relevant data.

Discovery 130

Discovery Depositions Litigation Technology 130

Discovery Advocate

MAY 20, 2020

As courts and litigants adapt to the new normal by instituting social distancing measures through remote hearings and depositions, how we preserve, collect and produce documents should not be an afterthought. Postpone that discovery until such a time it is safe and permissible to collect the potentially relevant data.

Discovery 130

Discovery Depositions Litigation Technology 130

Planet Depos

DECEMBER 15, 2024

There are countries that do not allow taking depositions for a number of reasons. This can obviously lead to numerous discovery problems that can make or break a case. So, what do you do if you need to depose a witness who resides in a country where depositions are not permitted? Pay for the witness travel.

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Depositions Discovery Witnesses Exhibits 52

Plaintiff Trial Lawyer Tips

JUNE 27, 2024

There are a volume of available ideas and outlines for the discovery deposition of a medical malpractice expert including advice to not take the deposition at all in some circumstances. FULL DETAILS 5 HOW MANY PAST DEPOSITIONS GIVEN? Here is a very basic outline, you can use as a format for your case.

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Depositions Witnesses Expert Testimony Discovery 100

Plaintiff Trial Lawyer Tips

OCTOBER 17, 2024

“By failing to prepare, you are preparing to fail” Benjamin Franklin In our office, my law partner and wife, Lita Barnett Luvera, legal responsibilities included preparing clients and witness for their deposition. Too often, lawyers tend to schedule an hour or two in their office on the day of the deposition to prepare their client.

Depositions 100

Depositions Interrogatories Witnesses Exhibits 100

E-Discovery LLC

OCTOBER 7, 2024

Fact discovery closed a day before the court’s opinion; however, it had been extended for 14 days “for the purpose of taking depositions that couldn’t be scheduled before the discovery cut-off.” Plaintiffs’ made their proposal to Meta on August 23 rd , prior to the September 30 th milestone cutting off discovery.

Discovery 130

Discovery Depositions Witnesses Litigation 130

E-Discovery LLC

AUGUST 16, 2024

13, 2024), the court began its decision of discovery issues with: “At the hearing Plaintiffs tried to walk back this [discovery] request and said it was limited to refund data, rather than a wholesale redo of non-custodial discovery. In that time, StubHub has taken 35 depositions and moved for summary judgment.

Interrogatories 130

Interrogatories Discovery Depositions Litigation 130

E-Discovery LLC

OCTOBER 22, 2024

DILATORY AND UNPERSUASIVE CHALLENGE TO DEPOSITION NOTICE “The Court need not resolve the factual skirmish over whether Washington agreed to the topics in NNI’s Rule 30(b)(6) notice to resolve the motion. The State’s newly-minted objections to the deposition topics come far too late , and are not persuasive.” Discovery Guideline 1.f).

Objections 130

Objections Depositions Discovery Witnesses 130

E-Discovery LLC

AUGUST 30, 2024

However, the Court also ordered that the parties have a court reporter transcribe the session and the Court reviewed the transcript to resolve post-meeting discovery disputes. For example, the defendant had noted the deposition of Ms. Jones to take place on Monday, February 27 th , which was the day before the discovery cutoff.

Depositions 130

Depositions Discovery Litigation 130

Attorney at Work

MAY 28, 2022

From time to time, opposing counsel may act in an uncivil or unprofessional manner during a telephone call, where there is no official record as there might be in a deposition or a written communication. During a Deposition. Opposing counsel may try to intimidate you during a deposition, hoping to fluster you if you are inexperienced.

Depositions 163

Depositions Objections Witnesses Discovery 163

E-Discovery LLC

JANUARY 15, 2025

Plaintiffs sought class certification discovery. Plaintiffs asserted, however, that Defendant insists on keeping its relevant custodians and data sources to itself (or at least forcing Plaintiffs to try and discover the same through interrogatories and depositions). Artsana USA, Inc., 2025 WL 50373 (S.D.

Discovery 130

Discovery Interrogatories Objections Depositions 130

E-Discovery LLC

MAY 31, 2024

This case is, in part, a trade secret case involving alleged misappropriation of source code, so requests seeking production of source code and related data are an expected part of discovery…. The court proceeded to resolve a number of other discovery issues. 1, 2023)( untimely discovery objection was waived); cf.

Interrogatories 130

Interrogatories Discovery Counterclaim Objections 130

E-Discovery LLC

OCTOBER 10, 2024

1, 2024), opens with the court’s statement that: The parties jointly ask to extend the discovery deadline and continue the trial. As the parties have demonstrated that they cannot manage the discovery process efficiently on their own, court oversight is necessary. Then, they “asked for and received 10 months to conduct discovery.”

Discovery 130

Discovery Mediation Depositions Interrogatories 130

E-Discovery LLC

MAY 30, 2024

PNI objected to discovery in part by asserting several privileges. After document was used in a deposition, PNI sought a “clawback” under the ESI Protocol. As it stands, the discovery period in this case expires on June 5, 2024 (a date the parties jointly requested approximately a month ago)….

Discovery 130

Discovery Depositions Objections 130

E-Discovery LLC

AUGUST 13, 2024

The Court “presided over a discovery dispute hearing related to Plaintiff’s motions to compel interrogatory requests and requests for production of documents, and related to a motion for a protective order filed by the Defendant.” Sometimes Discovery Disputes Do Not Bring Out the Best in Us – Part II (Jun. 7, 2024)(Simms, J.),

Discovery 130

Discovery Depositions Interrogatories Objections 130

E-Discovery LLC

JANUARY 8, 2025

The Red-D-Arc court reviewed the discovery and determined that plaintiff had made a prima facie showing of noncompliance with Rule 33(d) in particular that the information is not fully contained in the documents provided. This blog was initially posted on Electronic Discovery Reference Model. at *2 (cleaned up; citations omitted).

Interrogatories 130

Interrogatories Discovery Depositions Objections 130

The Cloud Court Blog

SEPTEMBER 28, 2022

“The deposition is the new trial.” – Jim Garrity, 10,000 Depositions Later podcast Jim Garrity, an employment attorney based in Florida, has produced scores of podcasts and published multiple books on the topic of depositions. And today, almost all testimony is in the form of deposition testimony for the reasons cited above.

Depositions 52

Depositions Witnesses Admissibility Litigation 52

E-Discovery LLC

DECEMBER 19, 2024

Plaintiffs later noted the deposition of a non-party, Dr. Fanning on March 29, 2024. Fanning and well before the deposition. The court also wrote that: The parties attempted to postpone Dr. Fannings deposition to allow time to review the Fanning Documents, but the court denied the request. Objections were due by July 10 th.

Depositions 130

Depositions Subpoenas Evidence Discovery 130

MyCase

MAY 7, 2024

Reading, reviewing, and crafting discovery responses isn’t just tedious—it’s downright time-consuming. MyCase has partnered with Briefpoint to help firms save time on discovery documents by eliminating repetitive work required for responses. What is Briefpoint? How Does the Integration Work? Top Benefits of MyCase and Briefpoint 1.

Discovery 52

Discovery Interrogatories Subpoenas Admissibility 52

Attorney at Work

OCTOBER 18, 2021

The truth is that, as long as pleadings are filed in a timely manner, discovery is completed, client questions are answered, and everyone complies with ethics rules, it really makes no difference if the work is done at 9 a.m. What really matters is their work is done well and they complete it on time.

Pleadings 328

Pleadings Depositions Case Management Legal Services 328

Attorney at Work

SEPTEMBER 15, 2022

One column might be dedicated to deadlines, another to discovery tasks, another to trial preparation. Evernote has the ability to capture and save notes and recordings from the web in a variety of different formats, whether these be emails, legal briefs, research files or discovery documents. A Powerful Project Management Panacea?

Trial Preparation 260

Trial Preparation Case Management Litigation Discovery 260

Plaintiff Trial Lawyer Tips

OCTOBER 31, 2024

THREE PRIMARY DEFENSE CLAIMS __ __ __ PLAINTIFF PROOF OF CAUSATION __ DEFENDANT CAUSATION DEFENSE _ PRELIMINARY STATUS REVIEW  Review local rules regarding deadlines and requirements DISCOVERY REVIEW Interrogatories  Review defendant’s answers to interrogatories. Note incomplete answers for motion. Supplement if needed.

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Cross-Examination Exhibits Interrogatories Opening Statement 100

E-Discovery LLC

AUGUST 21, 2024

See Felder Part 2 of 4: Defendant Sanctioned for Late Cancellation of Depositions. Plaintiff sought discovery of video footage “of an interaction” with her former manager and security personnel who had allegedly forcibly removed her from defendant’s premises. 4, 2023); Discovery About Discovery – When Was Duty to Preserve Triggered?

Evidence 130

Evidence Discovery Objections Litigation 130

Steno

JANUARY 6, 2025

Executive Summary Challenge: After decades of litigation experience, attorney Mike Marzban recognized that colleagues were often too shy to provide candid feedback on his deposition technique. He needed an objective way to evaluate his performance and identify potential blind spots in his questioning strategies.

Depositions 52

Depositions Objections Discovery Litigation 52

CaseFox

MARCH 23, 2023

Deposition or Negotiation: In many cases, the responsible party or their insurance company will attempt to negotiate a settlement with you rather than go to trial. Discovery: During the litigation process, both parties will engage in discovery, which involves exchanging information and evidence relevant to the case.

Interrogatories 97

Interrogatories Depositions Evidence Discovery 97

Complex Discovery

JULY 9, 2024

Grewal characterized their pursuit as a quest for “reasonable discovery” in response to the SEC’s June 2023 lawsuit. Paul Grewal, Coinbase’s Chief Legal Officer, emphasized the importance of these documents in a July 3 social media post.

Defense Strategy 122

Defense Strategy Precedent Discovery Depositions 122

E-Discovery LLC

OCTOBER 6, 2024

It noted that Mr. Shapiro even testified during depositions that he could not identify a single email that anyone read. During a deposition, HHI asked Mr. Shapiro, “I’m trying to find out whether you can identify whether anybody has used any of that information that was contained in those e-mails?” I can only speculate.”

Evidence 130

Evidence Discovery Affidavits Litigation 130

Lawmatics

NOVEMBER 7, 2023

E-discovery. Some of the tasks CoCounsel can potentially manage include document review, legal research deposition preparation, and contract review. AI allows law firms to target potential clients with personalized marketing campaigns based on status, matter type, location, and more. Email campaigns. Virtual assistants.

Legal Research 147

Legal Research Legal Strategy Precedent Depositions 147

Securities Docket

JANUARY 10, 2025

US Securities and Exchange Commission notes in its case against a consumer credit reporting corporation and investment fund manager are work product for litigation that cant be forced over in discovery, even if they are redacted, a federal judge ruled. Defendants Princeton Alternative Funding LLC, Microbilt Corp.,

Depositions 52

Depositions Witnesses Discovery Litigation 52

The Cloud Court Blog

JULY 11, 2023

July 11, 2023, 13:00 GMT MINNEAPOLIS, MN, USA, July 11, 2023/ EINPresswire.com / -- Setting the global standards for e-discovery, the Electronic Discovery Reference Model (EDRM) is pleased to announce Cloud Court, Inc. NEWS PROVIDED BY EDRM Global, Inc. And yet, what was said needs to be shared with the entire team.

Discovery 75

Discovery Witnesses Litigation Technology 75

Securities Docket

NOVEMBER 4, 2024

The discovery follows Coinbase filing two Freedom of Information Act (FOIA) requests against the Federal Deposit Insurance Corporation (FDIC) — the US agency insuring bank deposits — demanding they disclose information about the ongoing crypto crackdown among US banks.

Depositions 52

Depositions Discovery Insurance 52