Insights for litigation teams

Discovery & ESI

Preservation, requests and productions of text messages and other ESI — scaled for small and mid-size firms.

Discovery & ESIDeduplication and Threading for Message Reviews: Cut Volume, Not ContextEmail threading deduplication explained for review teams: hash-based dedup, inclusive emails, and why text messages need different matching rules.8 min read

Discovery & ESIDiscovery in Divorce Cases: A Workflow for Family Law TeamsDiscovery in divorce, step by step: intake, mandatory financial disclosures, issue-based requests, response tracking, exhibits and protecting sensitive data.8 min read

Discovery & ESIChoosing eDiscovery Software for a Small Law Firm: A Buyer’s FrameworkHow to choose eDiscovery software for a small law firm: define the need, compare categories and pricing, vet security and AI features, and run a real trial.8 min read

Discovery & ESIESI Discovery for Small Firms Without an eDiscovery BudgetESI discovery for small firms on a tight budget: how to map, preserve, collect and produce electronic evidence defensibly, and when a vendor is worth it.9 min read

Discovery & ESIThe ESI Meet-and-Confer Checklist: What to Settle Before Discovery StartsA meet and confer ESI checklist for Rule 26(f): preservation, custodians, search, production format, privilege and 502(d) orders, and text message data.8 min read

Discovery & ESILitigation Hold Letters: What to Include and When to SendHow to write a litigation hold letter: when the duty to preserve begins, what to include, client and opposing-party templates, and how to make the hold stick.8 min read

Discovery & ESIPrivilege Logs: A Practical Guide for Litigation TeamsHow to build a privilege log that holds up: Rule 26(b)(5) basics, required fields, sample entries, log formats, threads and attachments, and a QC workflow.8 min read

Discovery & ESIProducing Text Messages in Discovery: From the Phone to a Bates NumberA step-by-step workflow for producing text messages in discovery: collect exports, dedupe, review, redact, Bates number, hash and serve the response.8 min read

Discovery & ESIPDF, Native or Load Files? Choosing a Discovery Production FormatChoosing a production format in discovery: PDF vs native vs TIFF with load files, what the rules require, the right format per data type, and sample wording.8 min read

Discovery & ESIProportionality in ESI Discovery: Scoping Requests SensiblyProportionality in discovery, made practical: the six Rule 26(b)(1) factors as questions, ESI scoping levers, specific objections and a burden record.8 min read

Discovery & ESIDrafting Requests for Production of Text Messages (With Sample Language)Draft a request for production of text messages that gets usable data: groundwork, definitions, sample requests, form-of-production language and deficiencies.8 min read

Discovery & ESISpoliation of Text Messages: Preservation Duties, Risks and RemediesSpoliation of text messages explained: when the preservation duty starts, how texts get lost, how Rule 37(e) works, and what to do when messages go missing.8 min read

Discovery & ESISubpoenaing Phone Records: What Carriers Keep and What They Don'tHow to subpoena phone records from a carrier: which call and text records exist, why message content is usually out of reach, and a Rule 45 workflow.9 min read