2014 0722

http://www.blogtalkradio.com/e-discoverynutsandbolts/201/0/02/rule-2!"-con"erence-
preparation
#ule 2!$"% &on"erence 'reparation
(kay) we*ve been through the initial phases o" liltigation. +e*ve also answered any
summons or complaint in "oreclosure) submitted re,uests "or production o" documents)
interrogatories) -./ interrogatories) re,uest "or e0pert witnesses) etc. +e are now
perusing 1ill 2amilton*s 3.even 4eadly .ins o" the #ule 2!$"% *5eet-and-&onter*
&on"erence3 e0cerpt to ensure that we do not commit any o" the deadly sins. 6ow we
need to be prepared to speak intellently and articulate the reasons why we are re,uesting
the -./ and the nature and e0tent o" potentially relevant -./.1elow are some ,uestions
that will touch on a "ew o" the topics that should be addressed. 1. +hat are the issues o"
the case72. +ho are the key players in the case7. +ho are the persons most
knowledgeable about -./ systems74. +hen did preservation duties and privileges attach7
8. 2as a 39itigation 2old 6otice3 been issued7!. /" so) what steps have been or will be
taken to preserve -./77. +hat third parties hold in"ormation that must be preserved7:.
+hat -./ will be claimed as not reasonably accessible) and on what basis7;. /s there a
need "or an e-discovery special master or mediator710. 2ow much time is re,uired to
identi"y) collect) process) review) redact and produce -./7<ust to name a "ew.
=or more guidance on ,uestions to ask at the #ule 2!$"%) contact: >. <ohnson ?
>ssociates) 99& at www.a@ohnsonAediscoverynow.net or :::-802-08:!.
4/.&9>/5-#: +e are not attorneys. +e are not engaged in rendering legal advice. +e
are --4iscovery .olutions .pecialists. /" legal advice is re,uired) the assistance o" a
competent) ,uali"ied legal pro"essional should be obtained.