Tactical Discovery Consulting
The Federal Rules of Civil Procedure governing eDiscovery – Rules 16, 26, 33, 34, 37 and 45 – require attorneys to pay specific attention to electronic discovery issues. One of the most important is for the parties to participate in a mandatory Rule 26(f) “Meet and Confer” in advance of the Rule 16(b) scheduling conference.
During the early conference, parties are required to discuss specific issues related to the discovery of ESI and develop a mutually-agreeable discovery plan for the court’s approval. NightOwl consultants have the necessary experience with both practice and strategy working with outside counsel, IT, and legal, to develop the appropriate custom tailored discovery plan.
- Identification of relevant ESI sources
- Creation of a defensible litigation hold
- Creation of a collection plan to assure adequate preservation measures
- Quantification of active and legacy ESI
- Identification of ESI sources considered not reasonably accessible
- Assist counsel with development of a discovery plan for Rule 26(f) Meet & Confer
- Assist with the Rule 16 scheduling conference
- Defensible litigation hold and preservation measures
- Gain a strategic advantage at the 26(f) “Meet and Confer”
- Mitigate spoliation risks
- Documentation to support and defend the plan
Click here to download the NightOwl Tactical Discovery Consulting brochure.