Pitfalls Associated with Self-Collection of Data by Custodians: eDiscovery Best Practices

By Doug Austin


Last week, we covered the Burd v. Ford Motor Co. case where the court granted the plaintiff’s motion for a deposition of a Rule 30(b)(6) witness on the defendant’s search and collection methodology involving self-collection of responsive documents by custodians based on search instructions provided by counsel. In light of that case and a recent client experience of mine, I thought it would be appropriate to revisit this topic that we addressed a couple of years ago.


I’ve worked with a…

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