You Don’t Get a Second Chance to Make a First Document Production Request: eDiscovery Case Law

By Doug Austin

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In Allison v. Clos-ette Too, LLC, No. 14 CV 1618 (LAK)(JCF) (S.D.N.Y. Jan. 9, 2015), New York Magistrate Judge James C. Francis, among other motions considered, denied the plaintiff’s motion to compel the defendants’ production of electronically stored information (ESI) in native format after the plaintiff had previously requested (and received) ESI from the defendants without specifying the desired document format.

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Case Summary

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In this employment dispute, the plaintiff originally requested…

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