Thursday, October 20, 2011

A Proposal for Preservation Rule Amendments

In 2000, Judge Scheindlin warned, “It is safe to predict that federal courts will see a surge in the number of discovery disputes arising from electronic discovery.” (Scheindlin, S. Rabkin, J., “Electronic Discovery in Federal Civil Litigation: Is Rule 34 Up to the Task?” 41 B.C. L. Rev 327, 341 (2000). Six years later, amendments to the Federal Rules of Civil Procedure established guidelines for eDiscovery but failed to address preservation.

In 2010, Judge Scheindlin admonished, “By now, it should be abundantly clear that the duty to preserve means what it says.” (Pension Committee of the Univ. of Montreal Pension Plan v. Banc of America Securities LLC, et al., 685 F. Supp. 2d 456, 462 (S.D.N.Y. Jan. 15, 2010).

Unfortunately, what should be “abundantly clear” is still unclear. There are no rules clarifying preservation. The problem is especially vexing and expensive because preservation decisions happen so early, well before the parties meet under Rule 26 or the courts get involved and can limit the scope of discovery. By the time the rules kick in, the preservation decisions may be irreversible. Parties trying to decide if and how a lawsuit affects information management practices, back-up tape rotation practices, or email server policies, must apply the “better safe than sorry” rule and save unreasonably large volumes of ESI.

Will it take another 6 years to pass rules on preservation? The Judicial Conference Subcommittee on Discovery recently made excellent progress at a meeting in Texas identifying some of the problems created by the hole in the 2006 amendments.

To Continue Reading:  Click Here
--------------------------------------------------
Source:  eDiscovery Myth
By:  William Belt

0 comments: