August 2017 Ediscovery Case Summaries

Court Swiftly Denies Pop Star Defendant’s Motion for Adverse Inference, but Allows Defendant to Cross-Examine Plaintiff About Spoliation in Front of Jury
Mueller v. Swift, 2017 U.S. Dist. LEXIS 112276 (D. Colo. July 19, 2017)

Potentially Relevant Documents, Marked as Non-responsive, Unable to Remain a Secret in Trade Secret Theft Case
Nachurs Alpine Sols., Corp. v. Banks, 2017 U.S. Dist. LEXIS 104778 (N.D. Iowa July 7, 2017)

No Harm, No Foul: In Spoliation of Evidence Case, Court Unable to Apply Sanctions Without Prejudice
Snider v. Danfoss, 2017 U.S. Dist. LEXIS 107591 (N.D. Ill. July 12, 2017)

Failure to Abide by Court’s Discovery Order Leads to Sanctions
Bird v. Wells Fargo Bank, 2017 U.S. Dist. LEXIS 113455 (E.D. Cal. July 20, 2017)

Violation of Privacy is Not a Complete Defense: Supreme Court of California Grants Plaintiff’s Motion to Compel Contact Information of Fellow Employees
Williams v. Superior Court, 2017 Cal. LEXIS 5124 (Cal. July 13, 2017)

Belgium: The Ediscovery Capital of Europe

Hallo! Salut!

KrolLDiscovery is your international ediscovery resource, with current information about predictive coding in Australia and Ireland, ediscovery cooperation in Canada, fighting fraud in France, and data protection in the U.K., Japan and China.

Our 2017 ediscovery world tour brings us next to Belgium. As a divided country linguistically, culturally and geographically, Belgium has impacted the way leading international corporations and law firms are implementing new ediscovery practices.

Unique Ediscovery Practices in Belgium

To speak of Belgium is to speak of Brussels. It is undeniable that Brussels is at the center of the European Union and the host of the European Commission itself. Brussels is perhaps the most international city in the world, attracting leading international corporations and law firms. When it comes to ediscovery, Belgium has two distinct markets – international and national. As a result, Brussels has become one of the biggest ediscovery markets in Europe due to the size and the number of cases worked on in country. Law firms in Brussels work globally and rely on sophisticated ediscovery technologies for international cases.

Ediscovery Technology Needed Outside of Brussels

As the de facto capital of Europe, Belgium is at the center of the European ediscovery and yet, at the same time, removed from it. At the focal point, there are a massive amount of investigations in Brussels, yet there are no formal discovery requirements in country. As such, there is a greater need for education on the applications of ediscovery technology for companies and law firms who are operating outside of Brussels. A majority of Belgian ediscovery users are prominent, global law firms, working in competition-focused practice areas that involve multiple jurisdictions. By other law firms becoming educated on various ediscovery technology, it will improve how volumes of electronic data and documents in different languages are handled. Furthermore, corporations will be more likely to use ediscovery technology following a dawn raid and for large-scale compliance audits, culminating in more effective management of these legal matters.

Tips When Conducting Ediscovery in Belgium

  • Select an ediscovery provider that is as international as the case; this will go a long way to reducing cultural, legal and linguistic misunderstandings.
  • When there are large merger control cases, choose the best review technology available, with advanced analytics and predicative coding, in order to not be penalized for missing documents or deadlines.

Don’t be afraid to use ediscovery technology in new areas, such as arbitration or compliance audits. International firms in Brussels are increasingly using ediscovery technology in new legal scenarios that involve large data sets.

ILTACON 2017 – Pre-show Preview: Viva Las Vegas!

Look out Vegas, here comes ILTA (again)! After a brief 2016 hiatus to the Gaylord in National Harbor, Maryland, ILTACON is back in Las Vegas for 2017. This year’s conference will be held at the Mandalay Bay, just a couple blocks down the strip from Caesar’s Palace for those of you that attended ILTACON 2015.

When you reach the shimmering gold exterior of the Mandalay Bay, you might be overwhelmed with the abundance of food, entertainment and nightlife opportunities. So, just to make sure you don’t miss any of the valuable activities as ILTACON celebrates its 40th birthday, we thought you might appreciate a pre-show preview.

DATE: This year’s show occurs a week or two earlier than in years past: Make sure you have August 13 – 17 blocked off on your calendar.

SESSIONS: ILTACON is known for its stellar educational sessions and keynote addresses and this year is certain to not disappoint. For those of you tracking trends in predictive coding and analytics, make sure you attend the following session on Monday, August 14 from 1-2pm, where my colleague Tom Barce will be speaking as a part of the panel “Latest Trends in Leveraging Analytics in Litigation Support.”

DEMOS: Many vendors at ILTACON will be demonstrating their innovative products to make your legal technology jobs easier. KrolLDiscovery’s private suite (Surf C Suite) will be open to clients each day. We’ll keep food and beverages stocked for you to take a break from all the action. Plus, we’ll have space for you to learn more about our products, services and how we can help you. Schedule a demo with us today.

PARTIES: After a long day of sessions, make sure you make time for some refreshments! The exhibit hall will open on Monday night from 7-9pm with food, drinks and fun. The theme is “galaxy,” so bring your space-age costumes. Be sure to stop by KrolLDiscovery’s booth #500/502 for cool margaritas after a hot day in Vegas. We will also have snacks and happy hour at booth #500/502 on Tuesday and Wednesday; we look forward to seeing everyone at ILTACON 2017. Viva Las Vegas!

Document Review: MythBusters Edition

A couple years ago, I wrote a blog entitled, “Bust These 4 Myths on Your Next Document Review.” In this blog, I looked at four common document review myths and the realities behind the fallacies. Fast forward two years, there is no better time to revisit these myths to take the pulse of document review in 2017, considering the evolution of ediscovery technology, processes, rules and case law.

Myth #1: Document review just happens; you don’t really need a plan.

Since the adoption of the FRCP amendments we have seen courts admonish parties for:

  • Discovering new documents not in the original collection
  • Missing documents that should have been produced the first time around
  • Amassing costs for inefficient discovery methods

With document review technology at the top of its game, the misconception that document review is trivial is fading. In meeting with corporations and law firms, I hear legal teams appreciating the importance of having a review methodology. More often than not, those teams are inquiring as to how their processes can be improved.

2017 Document Review Lesson #1: Don’t procrastinate or wander aimlessly when it comes to review. Know your path from collection through production and be able to justify your methods.

Myth #2: Any attorney can conduct (or manage) a document review.

Today, document review is not the unglamorous chore of former times. With advancements in the review tools, increasingly senior attorneys are finding themselves immersed in document review more than in years past. The tools are easier to operate than ever before, and senior attorneys – typically subject matter experts on the case – are in the best position to review the most pertinent documents, especially if predictive coding is used.

At the same time, in order to fully leverage analytics and predictive coding features, the attorney will need advanced training or someone skilled in using these powerful features to guide them through. With formable technology at their fingertips and millions of documents to wrangle, today’s document reviewers are not only licensed and highly qualified attorneys; but also may have specific training and certifications in various document review platforms. Many have expertise in a different language other than English, or substantive knowledge in their practice area.

2017 Document Review Lesson #2: The days of brute force attorney review are over. Today’s document review requires subject matter experts in the case, working side-by-side with technology-minded attorneys that know how to maximize time and minimize costs.

Myth #3: All document review technology is equal.

What appears equal at face value, is not equal in action. While most major review tools function generally in a similar manner, there are enhancements unique to a particular provider and its tool set. From running searches and batching documents to using predictive coding or reviewing audio files, experienced document reviewers will recognize the fine distinctions of each provider’s platform, knowing when and how those features can be helpful. If they cannot answer a question, the reviewer should know how to get a hold of the technology provider’s technical support team to lend a hand.

2017 Document Review Lesson #3: Get into the technology weeds. Understanding the nuances of a provider’s technology is the only way to reap the benefits of a modern document review.

Myth #4: It will be obvious when you can stop review…when you run out of documents.

Predictive coding has changed how legal teams approach document review; however, even in 2017, the adoption of this is technology is marginal at best. Outmoded teams are still conducting linear reviews of every document, while progressive teams have figured out how to embrace predictive coding so that only the most vital documents are being reviewed for production. But, this does require a team that knows how to sample and interpret the metrics and reports generated by the technology.

2017 Document Review Lesson #4: The terminology related to predictive coding can cause one’s head to spin. Dust off your math skills (or leverage a specialist) – it’s the only way a savvy document review professional knows when a review is finished.

Leverage KrolLDiscovery for Document Review

Looking to modernize your document review methods?

KrolLDiscovery offers advanced document review services around the world, with fully managed review teams and up-to-date facilities in eight locations in four countries: Washington D.C., Chicago, Pittsburgh, Miami, Minnesota, London, Poland and Germany. KrolLDiscovery’s managed document review services teams provide you with specialized document review attorneys to meet your case needs. KrolLDiscovery review platforms are integrated with top-of-the line technology-assisted review and predictive coding features to search, categorize, redact and annotate documents. Our review teams utilize this technology to maximize efficiency through intelligent document prioritization and categorization, automated workflow, advanced search functionality and multilingual support.

July 2017 Ediscovery Case Summaries

Court Orders Partial Cost-Shifting, with Plaintiff’s Counsel to Bear ESI Production Costs for Lack of “Meaningful Meet-and-Confer Sessions”
Bailey v. Brookdale Univ. Hosp., 2017 U.S. Dist. LEXIS 93093 (E.D.N.Y. June 16, 2017)

A Tale of Two Phones: Court Forbids “Fishing Expedition” for Deleted Personal Data on Employer-issued Cell Phone, but Authorizes Discovery of Relevant Data from Personal Cell Phone
Tingle v. Hebert, 2017 U.S. Dist. LEXIS 88936 (M.D. La. June 8, 2017)

Court Finds Data Storage, Processing, Review and Production Costs as Non-Taxable in Post-Trial Motion
Wis. Alumni Research Found. v. Apple, Inc., 2017 U.S. Dist. LEXIS 86418 (W.D. Wis. June 6, 2017)

Sanctions Motion Denied Where There is No Prejudice or Intent to Deprive and Documents Could Have Been Restored or Replaced Through Additional Discovery
Eshelman v. Puma Biotechnology, Inc., 2017 U.S. Dist. LEXIS 87282 (E.D.N.C. June 7, 2017)

Court Denies Motion for Sanctions After Discovery Period Ends
Kennedy v. Supreme Forest Prods., 2017 U.S. Dist. LEXIS 77005 (D. Conn. May 22, 2017)

The DOJ and FTC; State and Federal Antitrust Laws; and Merger Enforcement in the Energy and Healthcare Sectors

New trends in antitrust law are impacting how agencies view company mergers. Previously, in part one of this video series, antitrust experts discussed how policy changes and technological advancements are impacting antitrust laws.

In part two of our antitrust video series, KrolLDiscovery shares the remaining videos from the 2017 Annual Spring Meeting of the ABA Section on Antitrust Law, made in collaboration with The Capitol Forum. Each video is organized with a short description to make it easier for you to decide which of these compelling videos to view first. Enjoy!

Are the Agencies Taking a More Aggressive Stance?

Watch: Aggressive Trends in Merger Review featuring George Paul, partner at White & Case LLP, as he discusses how this aggressive trend is reliant on several factors, such as structural presumptions and narrow market definitions.

Watch: Aggressive Trends Impact Efficacy of Mergers featuring Ian John, partner at Kirkland & Ellis LLP, as he discusses how this aggressive trend is impacting the timeframe of when transactions become finalized and how this trend will impact merger transactions in the future.

Watch: Unfavorable Antitrust Provisions Lead to More Litigation featuring Cliff Aronson, partner at Skadden Arps Slate Meagher & Flom, as he sees an increasing trend of companies negotiating unfavorable antitrust provisions, requiring them to go the full length of the investigation and possibly into litigation.

Merger Review in the Energy Sector

Watch: Mergers in the Energy Sector featuring Billy Vigdor, partner at Vinson & Elkins LLP, as he explains how market expansion in the energy sector may interplay with merger analysis and control under the Trump administration.

Mergers in the Healthcare Industry

Watch: Antitrust and Healthcare Consolidation featuring Joseph Miller, a partner at Crowell & Moring LLP, as he discusses current cases in the field of healthcare consolidation, the Affordable Care Act’s impact on healthcare consolidation and the future of healthcare consolidation.

Federal and State Engagement in Antitrust Law

Watch: Federal and State Relationships in Antitrust featuring Melissa Maxman, partner at Cohen & Gresser LLP, as she discusses the antitrust exemption in the Shipping Act and relationships between state and federal antitrust laws.

Watch: State Involvement in Antitrust Law featuring Kathleen Foote, senior assistant attorney general at the California Department of Justice, as she explains how states have become more involved in antitrust law and the impact states have on national mergers.

Fighting Fraud in France: How Sapin II and Ediscovery Technology Can Help

James Farnell, KrolLDiscovery, Legaltech News

Editor’s note: this article originally appeared in Legaltech News.

Fraud, corruption, bribery. Across the globe, these challenges hit close to home for legal and IT professionals regularly called on to collect, analyze and produce data in support of an active investigation or compliance audit.

In France, game-changing legislation is taking effect to strengthen anti-corruption efforts and U.S. businesses with global operations need to be prepared. The provisions of new anti-corruption legislation, Sapin II, have just come into force in France (as of May 2017). Sapin II, adopted on November 8, 2016, is modeled on the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.

Sapin II: The Key to Closing Loopholes in France

In 2005, Sapin II was first proposed and named after Michel Sapin, a French politician and France’s Finance and Economic Minister. Like many countries, France has attempted to combat fraud through multiple anti-corruption laws. However, these laws had several loopholes. The main aim of Sapin II was to strengthen existing anti-corruption legislation by implementing provisions that would close existing loopholes in France’s anti-corruption laws.

Sapin II is a comprehensive anti-corruption framework, some parts of which are more important than others. Below are a few key provisions of Sapin II, along with brief explanations.

1. France’s Expanded Jurisdictional Reach: Prior to Sapin II, French prosecutors had limited jurisdiction in bribery cases. Sapin II removed these restrictions and gave criminal prosecutors the opportunity to charge more offenders in bribery cases.

2. Creation of the French AntiCorruption Agency (AFA): Sapin II created a new administrative agency known as the AFA. The AFA has replaced the Central Service for the Prevention of Corruption (SCPC). It is monitored by a presidential appointee and a sanction commission. The AFA has four major responsibilities:

  • Prevent and detect corruption in the private and public sector;
  • Help companies implement compliance programs that are required;
  • Report violations of the law to prosecutors; and
  • Oversee the monitorships of corporations.

The AFA sends informative reports to the Justice and Budget Ministries to work together to keep up with fraud and anti-corruption strategies.

3. Compliance Program Requirement: Under Sapin II, a company must have a compliance program in place when there are more than 500 employees and the company has a gross revenue exceeding 100 million euros. This is applicable to both French subsidiaries and non-French companies who fulfill the above criteria. There are eight criteria that must be met in order for a compliance program to be deemed to be sufficient by the AFA. The most important criteria are that there must be corporate risk mechanisms and disciplinary procedures in place. Failure by a company to have a compliance program could lead to directors and managers being sanctioned by the AFA.

4. Whistleblower Protection Provision: Sapin II protects those who with good faith report against those who have violated any of France’s laws, international treaties where France is a party, or have threatened the public interest. In order for the whistleblower to receive protection he or she must notify a supervisor directly or indirectly. If the issue is not resolved within a reasonable amount of time then external parties may be notified and if three months have gone by and it is still not resolved, the public may be notified about the violation. Retaliation against a whistleblower can lead to both criminal and civil punishment.

5. French Deferred Prosecution Agreements (DPA): Sapin II’s DPA is modeled on the U.S. DPA. French corporations are forced to argue facts that have been listed by the DPA. Whether a corporation is punished depends on the judgment from a court through a public hearing. If found guilty, a fine of 30 percent of the company’s average revenue for the past three years must be paid to the French Treasury.

6. New Criminal Offenses and Bribery: It is now a crime for any company or individual to offer a donation, gift or reward to sway a public officer to abuse their discretion with public authority or government. This new criminal offense combines both French criminal law and anti-corruption efforts to stop and prevent fraud.

Sapin II and Ediscovery Technology

As legal and technology professionals in law firms and corporations begin to work under the new provisions of Sapin II, it will be increasingly important to turn to technology solutions to audit compliance programs and investigate fraud. Of particular interest within Sapin II, is the requirement that companies implement a procedure for assessing the effectiveness of a particular compliance program. The review of corporate electronic communication is one way of ensuring that organizations are complying with anti-corruption laws and ediscovery technology can be a critical piece of a thorough compliance audit. For example, the data analytics features in many leading ediscovery review platforms can help detect hidden or emerging compliance risks under anti-corruption laws.

In addition to assisting with a compliance review, legal professionals have increasingly leveraged ediscovery technology to facilitate the investigation and analysis of specific fraud matters. For example, in sensitive investigations, companies can rely on computer forensic experts to collect data and make use of mobile ediscovery technology which allows data to be processed, hosted and reviewed at the company’s premises, if need be. Data need not leave the premises while a sensitive investigation is underway. Most importantly, in France or anywhere around the globe, companies need to seek guidance from local experts to assist in the navigation of local data protection laws and with the collection, processing and analysis of electronic evidence in investigations and litigation.

Whether fighting fraud in France, investigating money laundering in Brazil or collecting data from a Chinese subsidiary in a U.S.-based litigation, organizations all over the world can manage a wide range of business and legal challenges using ediscovery technology.

Antitrust Law in the Era of Trump, Brexit and Technological Innovation

Recently, leading practitioners in antitrust law congregated in Washington, DC to discuss various effects the changing world has on antitrust laws and enforcement. At the Annual Spring Meeting of the ABA Section of Antitrust Law, KrolLDiscovery partnered with The Capitol Forum to create a video series of thoughts and insights from nationally-renowned antitrust experts.

Political change and technological advancement throughout the world has transformed policies and institutions enforcing antitrust law. The new administration of President Trump, Brexit, various policy changes and fast-moving technological advancements all create implications in the many fields of antitrust law. Part one of our video series will focus on how these changes are affecting antitrust law and litigation. Each video is organized with a short description to make it easier for you to decide which of these compelling videos to view first. Enjoy!

DOJ and FTC Involvement in Antitrust Law and Mergers

Watch: The Role of the FTC’s General Counsel featuring Bill Blumenthal, partner at Sidney Austin LLP, as he discusses his experience with antitrust law and merger regulations while acting as former General Counsel for the Federal Trade Commission.

Watch: Major Changes to the Antitrust Guidelines for International Enforcement and Cooperation featuring Jeff Jaeckel, co-chair of Morrison & Foerster’s antitrust law practice group, as he discusses the new DOJ and FTC antitrust guidelines on international law released in January 2017.

Watch: Competitive Effects featuring Ken Reinker, a partner at Cleary Gottlieb Steen Hamilton LLP, as he discusses how agencies review and analyze competitive effects and what impact the new administration will have on this analysis.

Technology’s Role in Merger Review and Antitrust Litigation

Watch: Big Data and Antitrust Enforcement featuring Maurice Stucke, of counsel at the Konkurrenz Group and law professor at the University of Tennessee, as he discusses big data’s impact on the traditional areas of antitrust enforcement and the resulting issues for mergers.

Changing Global Policies Impact U.S. Antitrust Laws

Watch: Global Antitrust Approach featuring Nick Gaglio, a partner at Axinn Veltrop & Harkrider LLP, as he discusses the importance of a global antitrust counsel, complexities of dealing with multiple jurisdictions and the effects of the new administration on global antitrust regimes.

Watch: Impacts of a Changing World featuring Jay Modrall, a partner at Norton Rose Fulbright, as he discusses differences in the Commission’s and CMA’s approach to transactions, the present and future impact of Brexit on global antitrust law, and how to mitigate the ensuing negative consequences.

In the next month, watch for part two of The Capitol Forum series, containing additional interviews with leading antitrust experts.

June 2017 Ediscovery Case Summaries

Should We Split It? Court Denies Defendant’s Motion to Be Relieved from Discovery Costs
Hawa v. Coatesville Area Sch. Dist., 2017 U.S. Dist. LEXIS 37675 (E.D. Pa. Mar. 16, 2017)

Hold Onto the Phone: Turning in Phone for Rebate has Preservation Consequences
Montgomery v. Iron Rooster-Annapolis, 2017 U.S. Dist. LEXIS 71338 (D. Md. May 9, 2017)

Court Grants Terminating Spoliation Sanctions Due to Abusive Litigation Practices
OmniGen Research v. Wang, 2017 U.S. Dist. LEXIS 78107 (D. Or. May 23, 2017)

Court Orders Parties to Meet and Confer to Determine Scope of Discovery Request
Elhannon v. F.A. Bartlett Tree Expert Co., 2017 U.S. Dist. LEXIS 58693 (D. Vt. Apr. 18, 2017)

Texas Supreme Court Weighs in on Native File Format Production
In re State Farm Lloyds, 2017 Tex. LEXIS 482 (Tex. May. 26, 2017)

50 States: Civil Procedure Rules in State Court – Part 2

Cue the fanfare…The new and improved rules map is here!

This spring, we worked to update our state ediscovery rules map – looking at each state’s civil procedure rules and how they approach ediscovery. Want to know which states have already adopted the 2015 Federal Rules of Civil Procedure (FRCP) amendments? Which states are still following the 2006 FRCP language relating to ediscovery? What states don’t have any ediscovery provisions whatsoever?

We looked at each of the 50 states (plus the District of Columbia), classifying them into five color-coded areas:

  • A pink state has substantially adopted the 2015 FRCP Amendments. There are three pink states: Arizona, Colorado and Wyoming.
  • A yellow state is actively taking on or considering new rules: either a version of the FRCP or its own. There are four yellow states: Florida, Kansas, Mississippi and Oklahoma.
  • A blue state has adopted and continues to follow the 2006 FRCP Amendments. There are 27 blue states, which includes every state not listed in another category.
  • A green state marches to the beat of its own drum, using unique language and standards. There are 14 green states: Connecticut, Delaware, Georgia, Illinois, Missouri, Nebraska, Nevada, New Hampshire, New York, Pennsylvania, Rhode Island, Texas, Utah and Washington.
  • A grey state signifies that the state has no ediscovery rules in place at this time. There are three grey states: Kentucky, South Dakota and West Virginia.

With so many jurisdictions, we want you to know the restrictions. From Hawaii to Virginia and Florida to Oregon, click each state to view its pertinent statutes and rules, along with suggestions for further reading about that state’s ediscovery protocols.

Ediscovery Rules & Statutes (Not Just a Pretty Map)

As we shared with you in our first blog on the 50 states of ediscovery, it has been a while since our map was updated. Some states made drastic changes, while others were happy with their own status quo. What happened in your state? Here is just a sample of what you will find.

Colorado Climbs Onboard

The Rocky Mountain State changed from grey to pink in 2015 when it adopted the then-upcoming FRCP amendments of the same year. A couple small differences remain: Colorado’s version reads Rule 26 in conjunction with Rule 1 to “secure the just, speedy, and inexpensive determination of every action.” Also, its Rule 37 does not mirror the FRCP.

Connecticut Calls its Own Shots

Some states adopted the 2015 FRCP, some did not and still others came up with their own version. Connecticut did all three, which earned it a swap from blue to green on our map. While Connecticut adopted the 2015 FRCP’s proportionality language, its sanctions wording is similar to that of the FRCP’s 2006 version. Interestingly, the state also includes an ethical requirement of “technological competence” as part of an attorney’s obligation to keep up with changes in the practice of law.

Illinois Gets Ahead of the Game

Illinois’ motto is “State Sovereignty, National Unity” and that sentiment is certainly reflected in its state Rules of Civil Procedure. Its many unique ediscovery provisions means it changed from yellow to green on our map. Illinois shares the FRCP’s emphasis on proportionality, with the state’s committee commenting that this amendment was added primarily to address the discovery of ESI. Illinois’ rules go even further by creating a list of ESI that should not be discoverable due to difficulty, but keeps its eye on the horizon by emphasizing flexibility as technology continues to advance.

Oklahoma: Amendments on the Horizon

Oklahoma adopted the 2006 FRCP in 2010. In early 2017, the state legislature proposed amendments to adopt the 2015 FRCP’s proportionality language and those amendments are still pending. Statute §12-3225 drops “liberally construed” and adds “construed, administered, and employed by courts and parties to secure” the just, speedy and inexpensive determination of action to mimic FRCP Rule 1. Its §12-3226 proposal mirrors the 2015 FRCP Rule 26(b) with one exception: it retains the phrase “reasonably calculated” just before the “relevant and proportional” wording. These proposed changes are enough to bump Oklahoma’s color from blue to yellow.

While the 50 states have rules almost as diverse as the states themselves, it is clear that the FRCP has had a role in shaping state civil procedure models. Over the next year, it is likely that more states will amend their rules to reflect the new FRCP, while others will continue to utilize their own unique standards.

If you practice in state court anywhere across the country, you need to know the discovery requirements, because they may be similar to the new FRCP or vastly different. Keep yourself in-the-know and check out each of the 50 states plus the District of Columbia today on KrolLDiscovery’s Rules and Statutes Map.

 
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