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., would include litigate, litigation, litigating, etc.). It is evident that, in this case, Attorney XXXX has ignored his duty to refrain from discovery efforts that are unreasonable or unduly burdensome or expensive in the context of these proportionality factors. In Wilbert v.
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