Proportionality-based eDiscovery is a goal that all corporate litigants seek to attain. Under Federal Rule of Civil Procedure 26(b)(1), parties may discover any non-privileged material that is ...

As a brief explanation, phased discovery limits the initial scope of discovery to the custodians and data most relevant to the issues in hopes of alleviating the potential burden and costs typically ...

Over the past decade, proportionality has become a defining feature of federal discovery practice, particularly in the context of electronically stored information (ESI). The 2015 amendments to the ...