Remove Litigation Remove Objections Remove Privileged Communication
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Another Approach to Drafting and Discovery of Litigation Hold Notices

E-Discovery LLC

By definition, a litigation hold notice is a communication from an attorney to a client regarding the duty to preserve potentially responsive information. [1] 7, 2025), the court held that litigation hold notices were privileged. Defendants did so and the insurers challenged the assertion of privilege. Grimm (ret.)

Discovery 130
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When is a Categorical Privilege Log Insufficient?

E-Discovery LLC

See Categorical Privilege Logs: Don’t Shoot a Mouse with an Elephant Gun (Mar. 25, 2021); Categorical Privilege Log Presented Interpretive Issues (Nov. In short, when it comes to privilege logging, proportionality principles should apply. Managing E-Discovery and ESI: From Pre-Litigation Through Trial” (ABA 2011), 355-58.

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A Request to File a Privilege Log Under Seal Was Denied

E-Discovery LLC

This blog focuses solely on the privilege log aspect of Sazerac. One litigant, RNDC, moved to seal certain exhibits to its response to a motion, including a privilege log. at *1 (cleaned up; citations and quotations omitted; emphasis added). Many courts have procedural rules or local rules that govern filing under seal.

Exhibits 130
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Good Help: Non-lawyer Assistants—Human and Virtual

WA Bar News

2000), for example, a paralegal moving laterally between firms on opposite sides of significant commercial litigation was screened from the matter involved shortly after arriving at the other firm rather than before. The paralegal later viewed 972 privileged emails and moved them into the firm’s case database. Because RPC 5.3(a)