What do we mean by “cooperation?”
Different viewpoints of in-house
counsel and outside litigators
How do you “cooperate” when there
isn’t an opposing counsel to
cooperate with?
Role of the court in fostering
cooperation
Cooperating to focus identification
of potential ESI sources
Cooperating on ESI preservation
Cooperating on ESI collection and
processing
Cooperating on review for responsiveness and privilege
Cooperating on production issues
Resolving discovery disputes without resort to motion practice