(1 hour or 2 hour Seminar) (Continuing Education Credit Available in Many Jurisdictions)

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The goal of this one-hour course is to provide attendees with the tools to propound discovery requests and to take 30(b)(6) depositions designed to gain the greatest possible understanding of the other party’s potential sources of electronically stored information.  

Too often, the opposing party gets away with an inadequate search of its records because the party propounding discovery has an incomplete understanding of its adversary’s computer systems.  Just as often, the attorneys and officers representing the opposing party do not themselves have a clear understanding of the information stored by such systems.  Information valuable to the case is consequently never produced, or is produced too late to support efficient resolution.  

This course will discuss how to use formal discovery to understand your adversary’s computer systems by:

(i)    reviewing sample initial disclosures;
(ii)    reviewing sample interrogatories and requests for production; and
(iii)     reviewing sample 30(b)(6) notices and deposition transcripts.