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Can You “Triangulate” for ESI? Not without the Other Party’s Permission.

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On October 4th of 2013, the Northern District of California issued a tentative ruling in a discovery dispute where the Defendant had “triangulated” its employees to identify who would possess relative discovery documents. It appears the Court had no issue with the “triangulation” technique. However, the Defendant neglected to discuss this strategy with the Plaintiff [...]

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