Rule 1 of the Federal Rules of Civil Procedure calls upon courts and litigants to “secure the just, speedy, and inexpensive determination of every action and proceeding.” And so, it comes as no surprise that technology assisted review (“TAR”) is being widely embraced by the legal profession.

What is TAR?

TAR (also called predictive coding,

De-duplication (“de-duping”) is the process of comparing electronic records based on their content and characteristics and removing duplicate records from the data set so that only one instance of an electronic record is produced when there two or more identical copies. De-duplicating a data set is a smart way to reduce volume and increase efficiencies

The role of electronically stored information (“ESI”) and new technologies has grown tremendously in recent years.  This growth has a direct impact on discovery specifically, and the practice of law, generally.   And so, the new practical reality is that attorneys need to be technologically literate and competent.  This should come as no surprise to those

Often viewed as a necessary evil, the Rule 26(f) conference can serve as an invaluable opportunity to meaningfully discuss discovery such that the process is streamlined and seeks to avoid unnecessary (and often costly) disputes.   Generally speaking, Rule 26(f), among other things, sets the deadline for the conference as soon as practicable and at least

On August 1, 2018, Judge Beetlestone (E.D. Pa.) granted Defendants’ motion for sanctions based upon unequivocal evidence that Plaintiffs manipulated and fabricated emails material to the litigation.  Although the Court imposed the drastic sanction of dismissing Plaintiffs’ complaint, the Court provided a detailed and instructive analysis supporting its ultimate conclusion.  The Court’s analysis, addressed below,