Responding Party’s Complaints of Financial Burden of Document Review Were Unsupported by the Evidence, Any Evidence

One of the largest cases in the U.S. today is a consolidated group of price-fixing cases in District Court in Chicago. In Re Broiler Chicken Antitrust Litigation, 290 F. Supp. 3d 772 (N.D. Ill. 2017) (order denying motions to dismiss Read More …

Disproportionate Keyword Search Demands Defeated by Metric Evidence of Burden

The defendant in a complex commercial dispute demanded that plaintiff search its ESI for all files that had the names of four construction projects. Am. Mun. Power, Inc. v. Voith Hydro, Inc. (S.D. Ohio, 6/4/18) (copy of full opinion below). Read More …

Project Cost Estimation Is Key To Opposing ESI Discovery as Disproportionately Burdensome Under Rule 26(b)(1)

If you are opposing ESI discovery as over-burdensome under Rule 26(b)(1), then you MUST provide evidence of the economic burden of the requested review. You cannot just say it is over-burdensome. Even if it seems obvious, you must provide some Read More …

Document Review and Proportionality – Part Two

This is a continuation of a blog that I started last week. Suggest you read Part One before this. Simplified Six Step Review Plan for Small and Medium Sized Cases or Otherwise Where Predictive Coding is Not Used Here is Read More …