Tag Archives: Electronic Documents

#6 Pretrial Agreements – Pick Five Custodians For Production

Each Side Will Pick Five Custodians for Production of Electronically-Stored Records. Electronic discovery has become the most expensive and time-consuming part of the pre-trial practice in most cases.  But pre-trial agreements can help to reduce the burden. Electronic discovery is so burdensome because requesting parties seek overbroad production of electronic documents, and because producing parties try to conduct a relevance and privilege review of every single electronic document.  In some large cases, each side will end up having several young lawyers spend weeks on end conducting relevance reviews of dozens of custodians’ electronic files.  This is extremely expensive, and not …


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