Full and Complete Production

Make Sure Your Initial Disclosures and Productions are Complete

August 21, 2018 Josh Gilliland Initial Disclosures, Request for Production

Identifying ESI that supports a party’s claims and is responsive to discovery requests comprises the detailed work of document review. Both workflows are extremely similar in that constructing searches are one way to find the relevant ESI. In a discrimination suit, the Defendants filed motions to compel the Plaintiff to[…]

What is Not a Full and Complete Production

April 3, 2018 Josh Gilliland eDiscovery

Responding to discovery requests requires analyzing what is actually being asked for in the request. The first step of analysis entails developing search strategies for date ranges, key words, and other search criterion to identify responsive discovery. Requesting parties have to prove a production is unreasonable or inadequate in order[…]