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Blogs about: Request For Production

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Boarding a Flight with Foreign Based Discovery for the Holidays1 comment

bowtielaw wrote 4 days ago: In the spirit of holiday travel, the Plaintiffs in Park v. Korean Air Lines Co., 2009 U.S. Dist. LEX … more →

Tags: Discovery, e-discovery, electronically stored information, eMail, Foreign Discovery, Motion to Compel, Search Terms

Speedy Delivery: Compelling Imaging & Searching of Everything3 comments

bowtielaw wrote 1 month ago: In a contract dispute regarding a shipping vendor, the Plaintiff brought a motion to compel the coll … more →

Tags: Discovery, Document Review, e-discovery, electronically stored information, eMail, ESI, Imaging Hard Drives, Search Terms, Motion to Compel

A Picture is worth a Thousand Words, but Sanctions are Priceless2 comments

bowtielaw wrote 2 months ago: The Defendants in Green v. McClendon, 2009 U.S. Dist. LEXIS 71860 (S.D.N.Y. Aug. 13, 2009) attempted … more →

Tags: e-discovery, Litigation Hold, electronically stored information, ESI, Duty to Preserve

Production Madness: The Covad Story Continues with New ESI Pitfalls1 comment

bowtielaw wrote 3 months ago: Understandably, taking an electronic document such as a spreadsheet, printing it, cutting it up, and … more →

Tags: e-discovery, electronically stored information, eMail, ESI, Form of Production, Imaging Hard Drives, Motion to Compel

Get Out the Check Book for Translating ESI into a Reasonably Usable Form in California

bowtielaw wrote 3 months ago: California Code of Civil Procedure 2031.280(e) states, in relevant part: If necessary, the respondin … more →

Tags: California Electronic Discovery Act, Discovery, e-discovery, electronically stored information, ESI, Form of Production, Reasonably Accessible, Reasonably Useable Form

California Rules on the Form of Production2 comments

bowtielaw wrote 3 months ago: Discussing the California Electronic Discovery Act provisions on stating the form of production in a … more →

Tags: Discovery, Form of Production, e-discovery

Don’t Argue Imaginary ESI Production Problems6 comments

bowtielaw wrote 3 months ago: In re NetBank, Inc., 2009 U.S. Dist. LEXIS 69031 (N.D. Ga. Aug. 7, 2009) has form of production argu … more →

Tags: Document Review, e-discovery, electronically stored information, ESI, ethics, Form of Production, Metadata, Motion to Compel, Native File

Rock Opera Discovery of Archived ESI

bowtielaw wrote 3 months ago: In re In re Operadora DB Mex., 2009 U.S. Dist. LEXIS 68078 (M.D. Fla. May 28, 2009), is the story of … more →

Tags: Discovery, electronically stored information, ESI, Form of Production, Meet & Confer, Reasonably Accessible, e-discovery

Turning Rule 26(a) Initial Disclosures into Rule 26(e) Supplemental Disclosures1 comment

bowtielaw wrote 4 months ago: What happens if more responsive documents are found after the case management order setting a requir … more →

Tags: Discovery, Initial Disclosures, Supplemental Disclosures, Motion to Compel

When You Have Over 100 "Any and All" Requests for Production, Don’t Complain About Lots of Documents to Review

bowtielaw wrote 4 months ago: When, as here, broad discovery requests lead to relevant documents being mixed in with seemingly irr … more →

Tags: Motion to Compel

Telling the Judge ESI is “Expensive” is not an Excuse for Failing to Produce1 comment

bowtielaw wrote 4 months ago: It is generally a bad sign when an opinion begins with a Court banning parties from filing more disc … more →

Tags: e-discovery, Discovery, electronically stored information, ESI, Motion to Compel

Spoliation is a “Grimm” Business

bowtielaw wrote 4 months ago: Magistrate Judge Grimm is no stranger to watershed opinions…and on occasion the 100 page a law revie … more →

Tags: Search Terms, Litigation Hold, Spoliation, e-discovery, Duty to Preserve

Swimming in the Deep End: Treading Water in e-Discovery Cases3 comments

bowtielaw wrote 4 months ago: This motion centers on electronic discovery. The proper handling of electronic discovery is a new an … more →

Tags: Discovery, e-discovery, electronically stored information, ESI, Form of Production, Metadata, OCR

What Should be the Ordinary Course of Business: Reviewing ESI in Litigation Support Software1 comment

bowtielaw wrote 4 months ago: The Defendants in Valeo Elec. Sys. v. Cleveland Die & Mfg. Co., brought a motion to compel the P … more →

Tags: CT Summation, Discovery, Document Review, e-discovery, electronically stored information, eMail, ESI, Metadata, Motion to Compel

Request for Production: Any and All Documents in the Past 46 Years Supporting the Overthrow of a Communist Government

bowtielaw wrote 5 months ago: Sometimes there is a case that is just too unique to pass up.  This is one of those cases. The Defen … more →

Tags: Discovery, Neutrality Act, Criminal Procedure

Motion to Compel Camera Phone Photo

bowtielaw wrote 5 months ago: Just as the Def Leppard Song Goes: All I got is a photograph — and it is not enough. (from the … more →

Tags: e-discovery, Form of Production, Discovery, eMail, electronically stored information, ESI

The Return of Covad Communications: Forensic Imaging of Databases & Email Servers3 comments

bowtielaw wrote 5 months ago: Magistrate Judge Facciola’s “Christmas Eve” opinion now has a sequel: Covad Communs. Co. v. Revonet, … more →

Tags: e-discovery, Search Terms, Discovery, eMail, Imaging Hard Drives, electronically stored information, ESI, Motion to Compel

The Plumbing of a Motion to Compel

bowtielaw wrote 5 months ago: In a product defect case about brass plumbing fittings, the Defendants fought a motion to compel ele … more →

Tags: Culling, deposition, Discovery, Document Review, e-discovery, electronically stored information, eMail, ESI, Litigation Hold

Follow the Court Order: If You are Ordered to Produce Searchable PDF’s, Don’t Produce TIFFs without Searchable Text

bowtielaw wrote 5 months ago: Gamesmanship is the harbinger of bad lawyer reputations.  Not obeying Court orders can be the death … more →

Tags: e-discovery, Form of Production, Motion to Compel, Discovery, deposition, Tiff, electronically stored information, ESI, Native File Production


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