ralphlosey
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All polls by ralphlosey
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Consider whether the parties will enter into a Federal Rule of Evidence 502(d) stipulation and order that addresses inadvertent or agreed production.
Posted 6 years on
poll.fm/9878072/embed
Consider & discuss with opposing counsel alternative ways to ID documents withheld on the grounds of privilege or work product to reduce the burdens of ID
Posted 6 years on
poll.fm/9878067/embed
Identify and determine how any production of privileged or work-product protected information will be handled.
Posted 6 years on
poll.fm/9878064/embed
Identify and determine the production format(s) that ensure(s) that any inherent searchability of ESI is not degraded when produced.
Posted 6 years on
poll.fm/9878058/embed
Identify and determine the extent, if any, to which metadata will be produced and the fields of metadata to be produced.
Posted 6 years on
poll.fm/9878056/embed
Identify and determine the formats in which unstructured ESI (e-mail, presentations, word processing, etc.) will be produced.
Posted 6 years on
poll.fm/9878054/embed
Identify and determine the formats in which structured ESI (database, collaboration sites, etc.) will be produced.
Posted 6 years on
poll.fm/9878052/embed
Identify and determine the time period during which discoverable information was most likely to have been created or received.
Posted 6 years on
poll.fm/9878044/embed
ID & determine custodians (by name or role) less likely to have discoverable information from whom discovery of ESI will be postponed or avoided
Posted 6 years on
poll.fm/9878043/embed
ID & determine custodians (by name or role) most likely to have discoverable information and whose ESI will be included in the first phases of document disc
Posted 6 years on
poll.fm/9878041/embed
Identify and determine sources of ESI less likely to contain discoverable information from which discovery will be postponed or not reviewed.
Posted 6 years on
poll.fm/9878040/embed
ID & determine sources of ESI most likely to contain discoverable information & that will be included in the first phases of FRCP 34 document discovery
Posted 6 years on
poll.fm/9878038/embed
Determine whether it is appropriate to conduct discovery of ESI in phases.
Posted 6 years on
poll.fm/9878036/embed
Understand & articulate producing party's quality-control method(s) to evaluate whether a prod is missing relevant ESI or contains too much Irrel. ESI
Posted 6 years on
poll.fm/9878032/embed
Understand & articulate search method(s), including specific words or phrases or other methodology, to be used to ID discoverable ESI & filter out rest
Posted 6 years on
poll.fm/9878028/embed
ID & determine whether there is relevant ESI that will not be preserved in accordance with FRCP 26(b)(1), requiring discovery to be proportionate to the nee
Posted 6 years on
poll.fm/9878024/embed
Consider whether any other limits on the scope of preservation or other cost-saving measures may be possible.
Posted 6 years on
poll.fm/9878020/embed
ID & estimate costs the parties agree to share to reduce overall discovery expenses, such as use of a common e-discovery vendor or other costsaving measures
Posted 6 years on
poll.fm/9878017/embed
Estimate the likely benefit of the proposed discovery.
Posted 6 years on
poll.fm/9878016/embed
Estimate the nature and scope of burdens associated with the proposed preservation and discovery of ESI.
Posted 6 years on
poll.fm/9878014/embed
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