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Court Denied Unopposed Motions for Protective Order and Approval of ESI Protocol

E-Discovery LLC

MIDDLE DISTRICT PRECEDENT The Orlando Health court cited Middle District Discovery (2021) §VIII (requiring cooperation amongst counsel regarding discovery of ESI and encouraging counsel to discuss protocols for exchange of ESI) and Local Access, LLC v. Discovery Plan” (Jan. Section VIII.F emphasis added]. 13, 2023).

Discovery 130
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Deposition Misconduct: Rules, Risks, and Remedies

WA Bar News

First, by focusing on these two areas, I definitely do not imply that these are the only issues that can arise in either depositions or discovery more broadly. 9 Washington’s appellate courts have also long spoken to the need to “play fair” in discovery generally and with witness testimony in particular. Washington RPC 4.4(a)