The Sedona Conference and its Working Group 1 on Electronic Document Retention and Production are pleased to announce publication of the final, post-public-comment version of The Sedona Conference Primer on Crafting eDiscovery Requests with "Reasonable Particularity" (Primer). The Primer addresses the problem of vague and overbroad discovery requests that clog the courts and increase litigation costs. It explores the history of the "reasonable particularity" standard and provides practical examples for drafting requests that comply with the standard. The Primer works in tandem with The Sedona Conference Federal Rule of Civil Procedure 34(b)(2) Primer, published in 2018, to ensure more efficient discovery, reduced costs, and decreased court involvement in discovery disputes. The public comment version of this Primer was published in November 2021. The editors carefully considered the comments that were submitted and, where appropriate, incorporated them into this final version. |
