With increasing frequency, the Court of Chancery is appointing Special Discovery Masters and Discovery Facilitators as discovery issues continue becoming more complex and time-intensive. With those ...

Image: Holley Robinson, EDRM with AI. In Gilbane Bldg. Co. v. School Bd. of Broward County, 2025 WL 1615553 (S.D. Fl. Jun 6, 2025), plaintiff moved to compel a “compliant” privilege log. The court ...

Of all of the tasks involved in complex litigation, few if any consume more time and money, while doing less to advance resolution of disputes, than the preparation of privilege logs. There is a wide ...

Privilege logs were never a fun part of business litigation. There are few tasks more tedious than logging individual pieces of correspondence by date, author, recipients, subject matter, reason ...

(For information on how to assert and show that the privilege and work product protections apply, the factors counsel should consider when preparing a privilege log, and when redaction of documents is ...

This was a monumental, collaborative effort among the team to take differing viewpoints and come to a consensus on a protocol that could work for both sides of the aisle.” — Cristin Traylor, director, ...