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Sample Documents and Model Orders & Motions

Sample Documents

Electronic Discovery Action Plan
This sample document provides an outline for developing an effective e-discovery action plan for you and your clients. It includes tips on preventative maintenance during the course of regular business and managing data in an efficient, cost-effective manner in response to a discovery request.

Chain of Custody Log
This sample document provides an overview of the information required to demonstrate that data has been properly copied, transported, and stored; that the information has not been altered in any way; and that all media has been secured throughout the process.

Model Orders & Motions

Model Order for Preservation of Electronic Data, from In re Initial Public Offering Securities Litigation, 21 MC 92 (SAS).

Model Order Concerning Electronic Discovery, from Prempro Products Liability MDL, 03-CV-1507 (E.D. Ark., November 17, 2003).

Model Order Regarding Discovery of Computerized Data, from Manual for Complex Litigation, Section 11.446

Model Order Regarding Preservation, described as a prototype of Form 40.25 in the Manual for Complex Litigation (4th Edition).

Model Order Requiring Underwriter Defendants to Complete Electronic Discovery, from WorldCom, Inc Securities Litigation, 02-Civ-3288 (S.D. New York, April 12, 2004).

Model Motion for Protective Order re Preservation of Electronic Data, from Genord et al. v. Blue Cross Blue Shield of Michigan, No. 03-72950 (E.D. Mich., March 2004).
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New ABA E-Discovery Resource on FRCP Amendments
The Discovery Revolution: E-Discovery Amendments to the Federal Rules of Civil Procedure The Discovery Revolution: E-Discovery Amendments to the Federal Rules of Civil Procedure, by Lewis and Roca LLP partner George L. Paul, Esq. and J.H. Cohn LLP director of IT security auditing Bruce H. Nearon, CPA. Order your copy from the ABA today...
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The information contained herein is not intended to provide legal or other professional advice. Applied Discovery encourages you to conduct thorough research on the subject of electronic discovery.