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.


(P.S. Stay tuned for my forthcoming whitepaper “How to Wear Down Your Adversary with Low-Grade Document Warfare” and for my forthcoming journal article “Claw Back Your Pride: Why Attorneys Who Use Clawbacks Are Planning for Failure” and for my other forthcoming journal article “Fake It ‘Til You Make It: Four Steps To Making It Look Like You Understand Predictive Coding” and for my forthcoming eBook  “Meta-Metadata: A Guide to the Data about Data about Data”.)

Roger Izova is recognized for his expertise and reputation in civil litigation. He is frequently asked to speak before professional and business groups regarding both substantive law and litigation strategy. Mr. Izova also oversees the Slip and Fall Clinic at Princeton Law.