Litigation Discovery Protocol Creation
Over many years, we have developed The Litigation Discovery Protocol, also known as an ESI Discovery Protocol. In fact, with its use by law firms throughout the United States, both federal and state court discovery orders have referenced it.
As your e-Discovery & Digital Forensic Expert, we help you strategize, negotiate, and implement a litigation Discovery Protocol. Critically, it will keep you in compliance with FRCP 26(f) meet and confer requirements. With this planning, you can limit the scope of discovery as well as describe how to retrieve the electronically stored information (ESI) you need. For example, other items that we cover in an ESI Discovery Protocol:
- Define a begin date and end date filter;
- List the phones, email accounts, computers, and social media accounts for collection;
- List of data types you need (e.g. text messages, emails, photos, voicemails, and computer files);
- Limit text messages and emails to or from certain people;
- Limit the information by search terms and phrases;
- Cull privileged communications;
- Layout a Discovery Schedule; and
- Specify the method of production.
Discovery Protocol Implementation
We will help you implement your Discovery Protocol to collect, cull, and prepare electronically stored information (ESI) for legal review. Of course, we exclude all attorney-client and other privileged communications from production to the other party. With the above-described filters, we hone your ESI to the most likely relevant items. Consequently, this greatly reduces costs and increases your response time.