As courts continue to wrestle with Rule 26(b)(2)(B), a trend of parties using proportionality as a barrier to e-discovery production emerges. Under Rule 26(b)(2)(B), the Federal Rules of Civil ...

I can’t listen to Mike Rugnetta’s podcast in the subway. I tell him this, and he’s gleeful; I’m not the first person to say so. It’s too easy to miss a transfer on one of his many trains of thought ...

“This court looks to due process to ‘determine the parameters for proper service,’ and we have held that certified-mail service is sufficient only if it is ‘reasonably calculated’ to reach interested ...