Fios

FRCP 26(f) Preparation

Responding to Discovery: FRCP 26(f) Preparation

Discovery Conference Analytics - FRCP 26(f) Preparation Fios specializes in helping clients prepare for FRCP 26(f) discovery conferences. Our consultants review actions already taken in response to a matter and gather detailed information about the organization’s electronically stored information (ESI). This includes:

  • Identifying all of the potentially responsive data repositories
  • Analyzing the ESI stored within those systems
  • Documenting preservation actions in a court-consumable manner
  • This formalized process serves as the foundation for successful “meet and confer” discovery conferences and provides counsel the leverage needed for negotiating a favorable scope of discovery – from collection requirements and forms of production to time lines and cost/burden arguments. As part of the process, clients receive documentation and data analytics to support voluntary disclosures and negotiations.

    With Fios’ Discovery Conference Analytics consulting service, you will get a clear understanding of your organization’s ESI, policies and procedures in advance of “meet and confer” negotiations and be ready to discuss:

  • Preservation actions – Know the issues regarding preservation of discoverable ESI, including actions taken to preserve potentially responsive evidence and any appropriate disclosures concerning inadvertent loss of data due to routine business operations.
  • ESI identification methodologies – Document the organization’s methodologies to clearly identify the data sources that are relevant to the matter or issues, including the scope and capabilities of those systems and the amount and types of ESI stored in those systems.
  • Collection protocols – Understand the organization’s computer systems, especially in the way ESI is stored, accessed, filtered and extracted – all of which can impact the ability to efficiently collect and cull potentially relevant ESI for discovery
  • Cost or burden arguments – Be prepared to argue cost and burden. Rule 26(b)(2)(B) states that a party need not provide discovery from sources that it identifies as not reasonably accessible because of undue burden or cost. Arguments need to provide enough detail to enable the requesting party to evaluate the burdens and costs relative to the likelihood of finding responsive information in the identified sources.
  • Production formats – Know what’s required at the end. Rule 26(f)(3) explicitly directs parties to discuss the form or forms in which ESI should be produced. The responding party has the right to object to the requested form(s) of production, if it clearly states the reasons for the objection and articulates the forms it prefers to use and why.

  • Fios Consulting Service Brief >
    FRCP White Paper >
    Meet & Confer Checklist >

    Relevant Resources

    ED101 - e-Discovery Fundamentals

    Article: Assess Preservation and Collection Practices

    First, the GC relied on old documentation to reduce the scope of discovery and ended up broadening it. Next, the GC negotiated common search terms across the entire enterprise rather than narrowing by custodian, department, location, or file attributes such as a date range.

    Advanced Electronic Discovery

    Webcast: A Waiver of Privilege? Understanding the Implications of FRE 502

    As the costs of litigation and e-discovery continue to soar, the U.S. Congress is considering legislation that would create a new Federal Rule of Evidence (FRE) impacting privilege. If enacted into law, proposed FRE 502 will substantially change current laws around the waiver of the attorney-client privilege and work product protection. Ronald J. Hedges, counsel at Nixon Peabody LLP and former U.S. magistrate judge, will discuss the history, purpose and potential impact of this important legisla

    Article: When Does a Document Become Evidence?

    Electronic evidence preservation and collection has been the bane of 21st century litigation. The failure of many corporations to account for their own information has compromised their litigation efforts even before stepping into the courtroom.

    Webcast: Advanced Litigation Issues in E-Discovery

    In light of the December 1, 2006 amendments to FRCP 26(b)(2), what should your company do to minimize risk and expenses associated with E-Discovery: Third parties who possess your data: how far does the litigation hold requirement extend? Cost shifting by non-parties under FRCP 45: the latest case law developments; Ensuring consistency and the question of national e-discovery counsel; Malpractice and counsel's duties: are the Zubulake and Morgan Stanley opinions a high water mark or the new stan

    Whitepaper: A Framework for Evidence Collection Planning and Assessment

    Inexpensive storage technology, expanding networks, the explosion of data, new data formats, and stricter regulations and tighter timeframes are putting enterprises at risk when they are required to respond to electronic discovery requests. For the purpose of this paper, enterprises incorporate all large organizations, including corporations, governmental agencies, regulated utilities, etc. Networks and data storage have moved beyond corporate walls and desktops.

    Article: “Save As Privileged” – The Next e-Discovery Answer?

    On September 20, 2005, the Judicial Conference Committee on Rules of Practice and Procedure sent the proposed electronic discovery amendments to the Federal Rules to the Supreme Court for its consideration.

    Emerging Trends

    Whitepaper: The Emerging Role of the Office of Technology Counsel

    Corporations are facing considerable changes where law and technology are concerned. There have been hints to the changes emerging for years. However, the forces causing this transformation have converged within recently and are necessitating a new way of thinking. Four factors are influencing these changes: The Amendments to the FRCP; The rapid growth of corporate data and networks; Technological innovations; Expanding capabilities and services offered by outside electronic discovery experts.

    Article: Are You Ready for E-Discovery Resulting From Subprime Litigation?

    The subprime mortgage crisis has evolved into a global financial crisis. All those affected — homeowners, regulators, politicians and investors — are clamoring for someone to blame. Investigations have begun, and class-action lawsuits are being filed. When a lawsuit is filed and the call comes for e-discovery, those who have not proactively mapped, organized and studied their electronic content universe may be caught by surprise. In the current environment surrounding e-discovery, a lack of read

    Webcast: Are You Ready for e-Discovery Resulting From Subprime Litigation?

    This webcast addresses the e-discovery risks faced by the financial industry as litigation and investigation around subprime transactions unfold, particularly around the smoking guns and large volumes of electronically stored information (ESI) that may exist somewhere in the e-universe. Those impacted will need to be prepared to answer questions around who knew what about the risk profile of the transactions, when did they know it, how were they represented, what were the expectations and what d

    e-Discovery Readiness & Planning

    Article: Assess Preservation and Collection Practices

    First, the GC relied on old documentation to reduce the scope of discovery and ended up broadening it. Next, the GC negotiated common search terms across the entire enterprise rather than narrowing by custodian, department, location, or file attributes such as a date range.

    Article: An IT Approach to FRCP Compliance

    Forrester's Barry Murphy conducts an executive podcast interview with Prashant Dubey, General Manager of Fios' Discovery Management Services Consulting group, to talk about e-discovery and the role of IT as a legal department business process mentor.

    Whitepaper: A Comprehensive Approach to Discovery Response Planning

    This paper outlines how taking a proactive, organized approach to discovery response planning can help enterprises predictably reduce the cost, time and risk inherent in the electronic discovery process; apply proven methodologies for developing and implementing comprehensive response plans; and leverage the planning process as a way to improve the interdependencies between the people, processes and technology required for defensible discovery response.

    Case Law / Rules

    Article: Driving to the FRCP 26(f) Conference

    An ESI Content Map is a concise summary of an organization’s electronic data sources for use by parties who don’t need to know every minute detail about the IT infrastructure.

    Webcast: ESI, Clawbacks, Cost Shifting and Disclosure: Understanding the Impact of Amended FRCP Rule 26

    Electronically Stored Information, cost-shifting arguments, clawbacks and disclosures. The list of new requirements and regulations is confusing and fraught with risk. Help your company understand the requirements of the amended Federal Rules of Civil Procedure (FRCP) with practical and proven suggestions as to how your company can mitigate the risks associated from inadequate e-discovery planning.

    Article: An IT Approach to FRCP Compliance

    Forrester's Barry Murphy conducts an executive podcast interview with Prashant Dubey, General Manager of Fios' Discovery Management Services Consulting group, to talk about e-discovery and the role of IT as a legal department business process mentor.

    Article: Preparing for an FRCP ‘Meet and Confer’

    In today’s litigious environment, both law firms and corporations are under mounting pressure to be much more proactive and process oriented when managing electronic discovery requests. This need is further compounded by the amendments to the Federal Rules of Civil Procedure (FRCP) that went into effect on December 1.

    Article: “Save As Privileged” – The Next e-Discovery Answer?

    On September 20, 2005, the Judicial Conference Committee on Rules of Practice and Procedure sent the proposed electronic discovery amendments to the Federal Rules to the Supreme Court for its consideration.

    Webcast: Are You Prepared for the New Meet-and-Confer Sessions?

    Rule 26(f) now requires that 21 days before a Rule 16(b) scheduling conference, the parties are to meet and confer to discuss any issues relating to preserving discoverable information; to develop a proposed discovery plan; to discuss any issues related to disclosure or discovery of electronically stored information (ESI), including the form or forms in which it should be produced; and to discuss any privilege issues, including the potential for a "clawback" agreement to be included in a court o

    Webcast: Privilege Under the Amended FRCP: Are You Protected?

    The amended Federal Rules of Civil Procedure require many procedural changes for lawyers and clients. But, what about privilege? In an effort to bring greater efficiency and reduce costs for litigants, new provisions effecting privilege can be landmines. In this Fios Series webcast, David M. Simon explores some of the potential pitfalls—and opportunities—that the FRCP changes have brought about.

    Article: Managing e-Discovery And Avoiding Sanctions Under The FRCP Amendments

    The Editor of Metropolitan Corporate Counsel interviews Brad Harris, Director, Discovery Center of Excellence, Fios, Inc. about the impact of the amendment to the Federal Rules of Civil Procedure.

    Webcast: FRCP – Discovery Obligations

    The FRCP Amendments have created an entirely new context for implementing common law preservation obligations involving electronically stored information. This webcast helps explain exactly how the Amendments impact the triggering and implementation of preservation of both accessible and inaccessible sources, including active data, backup media, legacy data and individual hard drives. It will also touch on related issues relating to the form in which information must be preserved.

    Webcast: e-Discovery and Retention: Living with the Rule 26(f) Conference and Rule16(b) Order

    When the amendments to the Federal Rules of Civil Procedure went into effect on December 1, a whole new playing field was created for companies having to comply with the new "meet and confer" requirements under FRCP Rule 26(f) and 16(b). What's more, it's still unclear as to exactly what must be prepared and presented at these conferences. Marie Lona will discuss the impact of FRCP Rules 26(f) and 16(b) and how to proactively plan so you can live up to the rules and stay in compliance with the r

    Webcast: Deja vu All Over Again: State Rules of Civil Procedure

    With just one year of experience under the Amended Federal Rules of Civil Procedure, the states are getting into the act. More than half of the states have enacted or reviewed rules for electronic discovery and are in varying stages of development and implementation. This Fios webcast brings back Tom Allman, a prominent voice in the legal community on electronic discovery rules and Mary Mack, technology counsel at Fios, for an hour-long review of what state's are doing, and not doing, about elec

    e-Discovery Standards & Best Practices

    Article: Start within for E-Discovery Success

    Interview with Brad Harris, Director, Discovery Center of Excellence, Fios Inc. and Barry Murphy, Principal Analyst at Forrester Research

    Fios Service Delivery Model

    The Fios Service Delivery Model was developed to address the unique requirements of e-discovery projects. The model graphically displays a "best practices" service methodology for project execution.

    Fios service model >

    Search the Fios Knowledge Center

    Search  |  Advanced Search

    Upcoming Webcasts

    12/2/2008 | register

    State vs. Federal e-Discovery Rules – Lessons Learned in 2008

    12/11/2008 | register

    e-Discovery Case Law Update - Winter 2008

    12/16/2008 | register

    The Sedona Update: Rule 502 and the New World of Privilege Waiver

    View all upcoming webcasts >

    View webcasts available on demand >

    Knowledge Center

    Sedona Update: White Collar Crimes & e-Discovery Implications

    View this webcast >

    A Comprehensive Approach to Discovery Response Planning

    Read the Whitepaper >



    Speak with an e-Discovery Expert

    Call (877) 700-3467 or use this
    contact me form.