Techniques to Narrow Production Scope

If you have even been engaged in litigation, you know that it is a time consuming effort. Once the complaint is filed, the opposing party is on guard to protect the interests of their client. This will include defending against ESI Discovery. Some of the main protections to be employed against your request for the production of electronically stored information will include:• Challenges to the scope of discovery• The discovery requests are too burdensome• The discovery requests are not relevant• The discovery requests are overbroad• The discovery sought is inaccessible• Challenges to samplingThere are techniques that can be deployed to minimize the effect of the above challenges and limit the amount of ESI to be produced, reduce costs, and narrow the scope of discovery.1. Narrow the subject matter of the request to the specific claims or defenses of the case.2. Limit the scope of discovery to a specific individual.3. Limit the search to specific types of files.4. Request load files with metadata! 5. Reach an agreement with opposing counsel as to what ESI is “not reasonably accessible”.For more information, contact A. Johnson & Associates, LLC at 888-502-0586 or www.ediscoverynow.net.DISCLAIMER: We are not attorneys. We are not engaged in rendering legal advice. We are E-Discovery Mediators|Arbitrators|Consultants. If legal advice is required, the assistance of a competent, qualified legal professional should be obtained.