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10 Best Practices: Forms of Production

Emails and their attachments represent an increasingly significant portion of ESI (Electronically Stored Information) collections and for good reason, too. The hundreds of billions of emails that are sent daily paint a comprehensive picture of our personal and professional lives, so it is no wonder that litigators must thoroughly and effectively review these collections for relevant case material. All too often, the “smoking gun” is hiding in .msg files and their attachments, but the peculiarities of email format can make this key evidence difficult to find, process for review, search, and produce. Watch to avoid the pitfalls of email discovery and find the critical evidence that breaks your case.

Key Points

  • Know the rules (FRCP/state/local)
  • Match your review request with your review approach
  • Know the common file deliverables in productions
  • ‘Meet and Confer’ (Rule 26) to your advantage
  • Request specific file types and metadata as needed
  • Track custodians & handle deduplication
  • Address placeholders, databases and unusual file types
  • Negotiate a comprehensive discovery order in complicated cases
  • Watch out for redactions traps
  • Increase privilege review accuracy with near dup checks

About the Speaker

Gene Albert is the CEO of Lexbe, and a frequent speaker and writer on litigation technology and eDiscovery topics. He is on the Planning Committee of the Texas State Bar eDiscovery Program. Gene has his JD from Southern Methodist University and his MBA from the University of Texas at Austin.

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