O’Magawd’s Model Stipulated Electronic Discovery Order

Many of my colleagues and acquaintances have asked for my best practices when it comes to forcing the other side into a swift settlement due to prohibitive “electronic discovery” costs. As any attorney worth his salt will know, burying the other side in documents is crucial to vigorous representation.

To that end, I have provided for your reference the O’Magawd firm’s model stipulated electronic discovery order for federal practice. Our attorneys are diligent in asking the court to enter it at the first hint the other side might have a crap ton of documents to exploit. It is an essential tool that should be in every litigator’s tool belt.

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