Discovery

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Discovery is where most cases are won or lost, and we run document production, depositions, interrogatories, and e-discovery to surface the evidence you need while keeping the cost of getting there under control.

Discovery is the engine of litigation and, too often, its biggest expense. We treat it as a strategy problem, not a paperwork exercise: figure out what evidence actually moves your case, go get it efficiently, and protect what the other side has no right to see. Our engineering roots help here, especially when the facts live in source code, databases, and logs that lawyers without a technical background struggle to read.

Targeted Written Discovery

Interrogatories, requests for production, and requests for admission set the terms of the fight. We draft them to lock in admissions and pin down the other side's story, and we craft responses and objections that protect privilege and proportionality without inviting motions. The goal is to get the documents and answers that matter, not to bury everyone in boilerplate that runs up bills and yields nothing useful.

Depositions That Build The Record

A well-run deposition can decide a summary judgment motion or break a case open before trial. We prepare with a clear theory of what each witness can give us, and we defend your witnesses so they testify accurately without volunteering trouble. Whether the deponent is a fact witness, a corporate designee, or a retained expert, we approach every session with the trial record in mind.

Practical, Cost-Controlled E-Discovery

Electronic discovery is where costs spiral and disputes multiply. We negotiate sensible ESI protocols, scope collection so you preserve what matters without sweeping in everything, and use technology-assisted review to cut review hours. When the data is technical, we know the systems involved well enough to find the relevant material instead of paying a vendor to guess, which keeps your e-discovery spend honest.

Frequently asked questions

They can ask for any information relevant to a claim or defense in the case, as long as the request is proportional to what's at stake. Courts weigh things like the importance of the issues, the amount in controversy, each side's resources, and how burdensome the request is. So a sweeping demand isn't automatically allowed just because the information exists.

E-discovery is the process of finding, preserving, collecting, reviewing, and producing electronic information like email, files, chats, and database records. It's usually the biggest discovery cost because the volume is huge and lawyers have to review it for relevance and privilege. Planning early for litigation holds, an ESI protocol with the other side, and tools like technology-assisted review is how you keep that cost in check.

You have to start preserving the moment litigation is reasonably anticipated, which is often before a complaint is even filed. That means issuing a litigation hold to everyone who might have relevant documents or data, telling them to stop deleting, and following up to confirm they're complying. If relevant material gets destroyed after that point, the court can impose sanctions, including an instruction telling the jury to assume the deleted evidence hurt your case.

Start with a privilege review before anything goes out the door, and log withheld documents on a privilege log so the other side knows what you're holding back and why. A clawback agreement under Rule 502(d) lets you retrieve anything privileged that slips through by mistake without waiving the privilege. For especially sensitive material, a protective order can limit who sees it. Planning this up front is far cheaper than fixing a mistake later.

The court has a wide range of options, from ordering the holdout to produce and pay your fees, all the way up to striking their pleadings, telling the jury to draw an adverse inference, or dismissing their case entirely. How severe the sanction is depends on how badly the party behaved and how much it hurt the other side. Minor, good-faith slips get treated very differently from deliberate stonewalling.

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