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#NELA16 - 2

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by

Brian Koncius

on 22 June 2017

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Transcript of #NELA16 - 2

#NE
LA
16

How To Deal With Discovery of ESI
Linda M. Correia
Correia & Puth
MEET &
CONFER
ASK, ASK, ASK!
NOT
YOUR TEMPLATE DISCOVERY!!!
THINK, THINK, THINK!
Ariana J. Tadler
Milberg LLP
Brian E. Koncius
Bogas & Koncius PC
DO IT AGAIN!?!
MEET & CONFER

FRCP 26
FRCP 34
FRCP 37
What do you have?
What do you use?
How?
Where?
Initial Discovery Protocols
What do you want from them?
Where is it?
What is it?
Who has it?
Technical Specifications
Production Format
Security Issues
Protective Order
Why do I need this?
Am I asking for the right stuff?
Why is this proportional to needs of the case?
Discuss Discovery
Be clear on needs
Do you need help?
Ask Defendant pointed questions.
The Sedona Conference Jumpstart Questionnaire
Discuss Preservation
Discuss Collection
Discuss Production
WHAT TO DO WHEN YOU GET WHAT YOU WANT?
Where to store production?
How to store production?
Data integrity and security are primary concerns
TAR WTF is TAR?
WHAT TO DO WHEN YOU DO NOT GET WHAT YOU WANT?
Motions to Compel
Motions for Remedial Measures & Sanctions
ESI = Electronically Stored Information
PRESERVE &
COLLECT
Demand actual answers.
WHAT TO DO WHEN YOU GET WHAT YOU WANT?
WHAT TO DO WHEN YOU GET WHAT YOU WANT?
Hmmmmm.....


...something stinks here!
Educate, Educate, Educate!
Build your record.
1A. Visit Mickey Mouse
TO DO IN LA:
1. Present at NELA
2. Catch a ball game
3. Celebrity Stalking err Sighting
4. Be photographed by paparazzi leaving a club with Lindsay Lohan.
5. Walk a red carpet.
6. Get discovered
7. Write a script
8. Get my SAG card.
9. Land a role in upcoming Star Wars
Full transcript