E-Discovery and Sample Litigation Forms
The following sample documents are in PDF format, unless otherwise noted.
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The letter advises clients of their obligation to preserve electronic data and contains recommended procedures for the use of e-mail.
Confidentiality and Joint Defense Agreement
This sample form can be used when your client’s and another lawyer’s client’s interest are aligned in litigation. Joint defense agreements can be important tools in preserving the attorney-client privilege and protecting communications between lawyers representing different parties that otherwise may not be privileged.
30(b)(6) Deposition Notice for Electronic Records Custodians
This notice will be especially helpful to practitioners who are still learning about the architecture of computer systems and how electronic data is stored.
Electronic Discovery Samples
- » Checklist for Rule 26(f) Meet and Confer
- » Instructions to Employees for Document Retention
- » Checklist for System Administrator Review
Other Samples
- » Notice of Removal (Diversity)
- » Stipulated Confidentiality Order
- » Amended Notice of Deposition
- » ANC’s Motion to Consolidate
- » Defendant Maple Grove Condominium Association’s Rule 26 Privilege Log
- » Defendant’s Initial Disclosures Pursuant to Fed. R. Civ. Proc. 26(a) and Local Rules 26.1
- » Defendant’s Motion to Compel Compliance With Subpoena
- » GE Capital’s Motion to Bifurcate Issues Relating to its Entitlement to Attorneys’ Fees from Issues to be Tried in the Underlying Trial
- » Hitachi’s Responses and Objections to Motorola’s Fourth Set of Requests for Production of Documents and Things
- » Memorandum in Support of Defendants’ Motion to Compel
- » Memorial Medical Center’s Request for Production of Documents
- » Notice of Depositions
- » Plaintiffs’ First Set of Interrogatories




