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Privilege Logs

EDRM - Electronic Discovery Reference Model

Court-Ordered Production of a “Destruction/Unavailable” Log

I have never heard of a “destruction/unavailable” log; however, in the comprehensive – indeed, exhaustive – decision of Leprino Foods Co. v. Avani Outpatient Surgical Center, Inc., 2024 WL 4488711 (C.D. Ca. Sep. 30, 2024),...more

EDRM - Electronic Discovery Reference Model

[Webinar] Scary Important eDiscovery Case Law Decisions for October - October 31st, 1:00 pm - 2:00 pm ET

Afraid you won’t be up to date on important case law? Our October 2024 monthly webinar of cases covered by the eDiscovery Today blog will remove all your fears! During the webinar we will discuss disputes related to relevance...more

McGuireWoods LLP

When Do Courts Conduct an In Camera Review of Withheld Documents?

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Given the bare bones nature of many privilege logs, courts sometimes may be called upon, or themselves decide, to review withheld documents in camera to assess the grounds for the documents’ withholding. A handful of courts...more

McGuireWoods LLP

Two August Decisions Assess Privilege Protection for Employee-to-Employee Communications

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Corporate litigants’ privilege logs often trigger privilege disputes about internal corporate communications not involving a lawyer — because the log does not mention a lawyers’ participation. But there are at least two...more

Marshall Dennehey

Florida’s Third District Court of Appeals Quashes Trial Court’s Order Compelling Production of Certain Claim File Documents

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Vault Reciprocal Exchange v. Luria, et al., 2024 WL 948632 (Fla. 3rd DCA 2024) - During discovery, Vault Reciprocal Exchange responded to Luria’s request for production and preemptively filed a privilege log, which objected...more

EDRM - Electronic Discovery Reference Model

[Webinar] Privilege Logging in the Age of GenAI: Mitigating Burdens and Risks (CLE) - September 9th, 1:00 pm - 2:00 pm ET

Burdensome. Time-consuming. A drain on resources. This has characterized traditional privilege logging process. In May 2024, The Sedona Conference Working Group 1 introduced its Commentary on Privilege Logs, offering tools...more

EDRM - Electronic Discovery Reference Model

“Attachments to Attorney-Client Communications May Be Withheld as Privileged, Without an Independent Basis for Privilege,” But….

In Linet Americas, Inc. v. Hill-Rom Holdings, Inc., 2024 WL 3425795 (N.D. Ill. Jul. 15, 2024), the court held that “attachments to attorney client communications may be withheld as privileged without an independent basis for...more

Kilpatrick

Taming the Privilege Log Beast

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There are few things more dreaded in discovery than the time-consuming, tedious, onerous, beastly privilege log – especially in complex litigation matters involving thousands of pages of documents. These logs, however, are a...more

EDRM - Electronic Discovery Reference Model

Discovery About Discovery – When Was Duty to Preserve Triggered?

In Linet Americas, Inc. v. Hill-Rom Holdings, Inc., 2024 WL 3425795 (N.D. Ill. Jul. 15, 2024), the court “allowed [defendants] Hillrom to take limited discovery about when [plaintiff] Linet’s duty to preserve may have...more

EDRM - Electronic Discovery Reference Model

July’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published July 24, 2024 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the...more

EDRM - Electronic Discovery Reference Model

Agreement in ESI Protocol to Provide a “Metadata-Only” Privilege Log Was Enforced

In Linet Americas, Inc. v. Hill-Rom Holdings, Inc., 2024 WL 3425795 (N.D. Ill. Jul. 15, 2024), the court enforced an ESI Protocol that called for a “metadata-only” privilege log, even though parts of the metadata were...more

EDRM - Electronic Discovery Reference Model

The Standard for In Camera Review of Assertedly Privileged Documents

The purpose of a privilege log is to provide sufficient information for the recipient of the log to determine whether the withheld information is, at least on its face, privileged.  In short:  “Trust, but verify.”  See,...more

McGuireWoods LLP

The Consequences of a Bad or Tardy Privilege Log

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Every court seems to require litigants to log documents they withhold based on privilege or work product claims. Perhaps not surprisingly, hardly any log goes unchallenged by the adversary. Most of these disputes eventually...more

Association of Certified E-Discovery...

[Event] The Great eDiscovery Debate - July 16th, Chicago, IL

Get ready for some epic showdowns as Chicago ACEDS and Cimplifi present The Great eDiscovery Debate on July 16th!...more

EDRM - Electronic Discovery Reference Model

When is Failure to Provide a Timely Privilege Log Excusable?

In Melton Properties, LLC v. Ill. Central R. Co., 2024 WL 3015749 at *5 (N.D. Miss. June 14, 2024), the court listed the factors to consider in deciding when the failure to provide a timely privilege log is – or is not – a...more

EDRM - Electronic Discovery Reference Model

June’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published June 18, 2024 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the...more

Farrell Fritz, P.C.

Rattling the Attorney-Client Privilege Cage – A Lesson in Avoiding Waiver of Privilege Under the Common-Interest Doctrine

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In many cases, clients tend to place their trust, and often their livelihood, in the hands of their attorney. This expectation can be easily traced back to the attorney-client privilege, one of the oldest common-law...more

Array

This Week in eDiscovery: Ruling Says Hyperlinks Aren’t Traditional Attachments, Sedona Conference’s Commentary on Privilege Logs...

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the week of May 27-June 2. Here’s what’s...more

EDRM - Electronic Discovery Reference Model

May’s Notable Cases and Events in E-Discovery

[Editor’s Note: This article was first published May 15, 2024 and EDRM is grateful to Tom Paskowitz and Robert Keeling of our Trusted Partner, Sidley, for permission to republish. The opinions and positions are those of the...more

McGuireWoods LLP

Courts Disagree About Privilege Log Requirements: Part II

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Last week’s Privilege Point described one court’s incredible requirement that litigants identify everyone who learned of a withheld document’s content — even if they were not shown as a recipient....more

Vinson & Elkins LLP

Mastering Automated Privilege Logging: How Litigants Can Maximize Efficiency and Limit Expense

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Privilege logging is one of the most time-consuming, expensive, and contentious components of discovery. Federal Rule of Civil Procedure 26(b)(5)(A), which governs the withholding of privileged material, provides little...more

EDRM - Electronic Discovery Reference Model

There’s No Right or Wrong Answer – But There Are Mistakes

In Rayome v. ABT Electronics, 2024 WL 1435098 (N.D. Ill. Apr. 3, 2024), the court wrote that “it would be in the parties’ interest to reach a negotiated result. It should not be forgotten that a party could be ‘right,’ but...more

UnitedLex

Powering Privilege Logging with Generative AI

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In the ever-evolving landscape of legal technology, artificial intelligence (AI) is transforming the way legal professionals approach their daily tasks. One significant stride in this realm is the advent of Large Language...more

Array

This Week in eDiscovery: EDRM Guidelines for GDPR Compliance, What Information is Enough for a Privilege Log, and More

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Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the week of April 1-7. Here’s what’s...more

EDRM - Electronic Discovery Reference Model

What Happens When Parties Fail to Negotiate a Privilege Log in Good Faith?

In Kyle Rayome v. ABT Electronics, 2024 WL 1435098 (N.D. Ill. 2024), the court wrote that it “would prefer this case not go to the dark place where attorneys on one side demand that the attorneys on the other side provide...more

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