A Wake Up Call Revisited: Read the Rules & Don’t Argue “Not Reasonably Calculated” in Federal Courts
E-Discovery LLC
FEBRUARY 25, 2025
wrote: It is time, once again, to issue a discovery wake-up call to the Bar in this District: the Federal Rules of Civil Procedure were amended effective December 1, 2015, and one change that affects the daily work of every litigator is to Rule 34. Forrest, 2017 WL 773694, at *1 (S.D.N.Y. accord Avila v. Target Corp., 26(d)(3)(A).
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