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Start by reviewing all of the motions, briefs, discovery responses, and pleadings. Extract any dates that you come across during that review and put them into a chronology. As you’re doing your review, create a master to-do list for that case where you can keep notes about the things that you come across.
“Professed technological incompetence is not an excuse for discovery misconduct” is not a court holding you want to see (James v. Finally, depending on the technology used for the exam, examinees could be asked to convert a Word document into a PDF and remove any metadata damaging to their client. CV 8931-VCL, 2014 WL 6845560 (Del.
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