Deduplication Between Parties

Even before either side does a first-pass review of their collected documents, they can easily identify which potentially-discoverable documents both sides already have in common. This process would be fast, inexpensive, and easy, and would allow new kinds of...
The EDiscovery Privilege Order

The EDiscovery Privilege Order

As shown below, any federal court has the absolute statutory authority, which it should exercise immediately upon the filing of any action, to unilaterally enter an order that provides as follows (an “EDiscovery Privilege Order”): 1) No communications...
The EDiscovery Communication Privilege

The EDiscovery Communication Privilege

The following Order encourages disclosures between the parties about ediscovery by making certain communications non-discoverable and inadmissible, and by ensuring that those communications will not waive any otherwise applicable privilege or protection. It’s...