Rule 26(f) Conference Preparation

Okay, we've been through the initial phases of liltigation. We've also answered any summons or complaint in foreclosure, submitted requests for production of documents, interrogatories, ESI interrogatories, request for expert witnesses, etc. We are now perusing Bill Hamilton's "Seven Deadly Sins of the Rule 26(f) 'Meet-and-Conter' Conference" excerpt to ensure that we do not commit any of the deadly sins. Now we need to be prepared to speak intellently and articulate the reasons why we are requesting the ESI and the nature and extent of potentially relevant ESI.Below are some questions that will touch on a few of the topics that should be addressed. 1. What are the issues of the case?2. Who are the key players in the case?3. Who are the persons most knowledgeable about ESI systems?4. When did preservation duties and privileges attach?5. Has a "Litigation Hold Notice" been issued?6. If so, what steps have been or will be taken to preserve ESI?7. What third parties hold information that must be preserved?8. What ESI will be claimed as not reasonably accessible, and on what basis?9. Is there a need for an e-discovery special master or mediator?10. How much time is required to identify, collect, process, review, redact and produce ESI?Just to name a few. For more guidance on questions to ask at the Rule 26(f), contact: A. Johnson & Associates, LLC at www.ajohnson@ediscoverynow.net or 888-502-0586.DISCLAIMER: We are not attorneys. We are not engaged in rendering legal advice. We are E-Discovery Solutions Specialists. If legal advice is required, the assistance of a competent, qualified legal professional should be obtained.