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ESI Protocol Part III: Top 10 Situations You Can Avoid with a Protocol - E-Discovery, Information Governance & Cyber Security Section News

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E-Discovery, Information Governance & Cyber Security Section News

Posted on: Mar 30, 2021

Intro by Helen Geib, Hoover Hull Turner LLP

There are many advantages to taking a proactive approach to production format – and corollary risks from being reactive instead. This post from the E-Discovery Assistant blog identifies ten common problems that stem from not addressing production format and related issues at the outset of discovery. These include missing metadata (dates, filepath, custodian, etc.), paying to OCR images converted from searchable electronic documents, unusable file formats like multi-document PDFs and confusion over the timing and content of privilege logs. The authors advocate for ESI protocols such as the USDC Southern District of Indiana’s ESI Supplement to the Case Management Plan. Practitioners in other courts can use the Southern District’s ESI Supplement as a roadmap for negotiating ESI protocols in their cases.

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