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Speeding Up E-Data Review

It’s impossible for counsel to look at every single document that’s part of a large-scale e-data review—doing so would be prohibitively costly and time-consuming. But it’s also unacceptable to blindly produce documents to the opposing party. You can safeguard clients without excessive expense by taking time at the beginning of the case to make some determinations about how to conduct the review. Try one of these four ways to speed up e-data review. Continue reading

5 Steps to Responding to a Deposition Notice

After receiving a deposition notice or subpoena, counsel should to take a careful look at the documents served and make decisions about how to proceed. To organize the process, follow these five steps. Continue reading

To Meet and Confer, You Need to Talk

If you have a “dispute concerning discovery,” the law requires that you try to resolve it informally by conferring with the opposing side. This meet-and-confer requirement can be met in person, by telephone, or by letter. But a letter or email alone generally won’t cut it; to really meet and confer, you need to talk to opposing counsel. Continue reading

Are Insurance Agreements Discoverable?

The existence of insurance is often key to a lawsuit and one of the first orders of business in discovery. There are statutory provisions allowing for discovery of the existence and contents of insurance agreements—as well as limits on it. Continue reading

Before Requesting Discovery, Have a Plan to Enforce It

When starting discovery, your focus is on the specific requests you will make. But don’t forget to have a plan to enforce your discovery efforts. Continue reading

Deadlines for Motions to Compel

thinkstockphotos-471597236The timing of a motion to compel depends largely on whether responses have been served. Here’s a review of the timing in common situations and a handy chart with the time limits. Continue reading

Who May Attend a Deposition?

thinkstockphotos-155804580Generally, depositions are a fairly intimate gathering with only the necessary attendees. But what do you do if you’re surprised by an unwelcome person who insists on being present? Continue reading

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