The Sedona Conference Institute (TSCI) Presents: 2022 eDiscovery Negotiation Training: Practical Cooperative Strategies

Tuesday, March 29, 2022 - 12:00pm to Thursday, March 31, 2022 - 4:45pm

Online (Zoom)

Join leading jurists, in-house counsel, outside counsel, and eDiscovery experts online (via Zoom) on March 29-31, 2022, for this unique program which helps participants develop practical skills in eDiscovery negotiation. In the program, participants are trained to negotiate effectively with opposing counsel, in order to ensure efficient, cost-effective fact-finding, and avoid unnecessary disputes, consistent with Rule 1 of the Federal Rules of Civil Procedure and the ethical obligations of attorneys as officers of the court.

Since the pandemic began, the parties to litigation have been conducting Rule 26(f) conferences online and the courts have been conducting Rule 16 conferences online.  Most courts have found online conferences to be very effective and more efficient than in-person conferences and have announced that online Rule 16 conferences are here to stay.  Given that much of pretrial practice has now moved online, our eDiscovery Negotiation Training program will be conducted online to mirror current pretrial practice.  

Program Description

The program features a heavily participatory format. Through use of a litigation hypothetical, faculty demonstrations, and mock negotiation and hearing exercises, participants explore practical cooperative strategies to avoid or resolve conflicts that commonly occur in the preservation, collection, production, and use of electronically stored information.

Under the supervision of the experienced faculty, participants take part in three mock Rule 26(f) conferences focusing on scope of discovery, preservation, form of production, privilege, and social media, in both breakout sessions and plenary sessions. Some participants also have an opportunity to participate in a mock Rule 16(b) case management conference during a plenary session, with one of our judicial faculty members presiding. The faculty of veteran trial lawyers, eDiscovery experts, and judges provide opportunities for dialogue, demonstrations, and valuable critique of the attendees' performances in the exercises.

Application for an Invitation

Participation in this program is significantly limited to ensure a high instructor-attendee ratio and a strong participatory experience. Participants receive personalized feedback and critique from faculty members, and in many cases, have the opportunity for a one-on-one dialogue with faculty members. For this reason, it is necessary to limit the number of participants. Additionally, the program is "invitation only" to ensure a proper balance of participants.

3/21/22 Update: While seats remain available, please note, this program requires significant advance preparation, including review of a preparatory webinar and the hypothetical case file. In addition, participants are assigned to teams and need to meet with faculty advisors in advance of the program. Given that the program is now just one week away, joining the program at this time can potentially be disruptive. Therefore, we can no longer guarantee an invitation to the program if you would have otherwise been accepted.


Perkins Coie LLP

Washington, DC

Baylor Law School

Dallas, TX, USA


Ralph Artigliere LLC

Clemson, SC, USA


Armonk, NY, USA

Volkswagen Group of America

Herndon, VA, USA


Philadelphia, PA, USA

Beasley Allen

Montgomery, AL, USA

Georgetown Law

Alexandria, VA, USA

Innovative Driven

Alpine, UT, USA

Bolch Judicial Institute at Duke Law School

Durham, NC, USA

Robbins Geller Rudman & Dowd LLP

San Diego, CA, USA


New York, NY, USA

King & Spalding

Atlanta, GA, USA

Shaw Keller LLP

Wilmington, DE, USA

Appellate Division, First Department, Supreme Court of the State of New York

New York, NY, USA


New York, NY, USA

U.S. District Court, Southern District of Florida

West Palm Beach, FL, USA

Repario Data

Milford, CT, USA

Hill Ward Henderson

Franklin, TN, USA


Spring, TX, USA


Redmond, WA, USA

JPMorgan Chase

Newark, DE, USA

Redgrave LLP

Chicago, IL, USA


Cleveland, OH, USA

DLA Piper

New York, NY, USA

U.S. District Court, Eastern District of Texas

Plano, TX, USA

iDS, Ltd

London, United Kingdom

FTI Consulting

Philadelphia, PA, USA

Littler Mendelson P.C.

Philadelphia, PA, USA


Time Session Panelists
  Tuesday, March 29, 2022 (all times EDT)  
12:00 — 12:15 Welcome & overview Hughes, Schultz, Weinlein
12:15 — 12:45 What do Judges Expect: A Dialogue with Judges Artigliere and Grimm Artigliere, Grimm, J.
12:45 — 1:00 Break  
1:00 — 2:15 Scope, Form and Preservation:  Breakout Session Entire Faculty
2:15 — 2:30 Break  
2:30 — 4:00 Scope, Form and Preservation:  Plenary Session Gronborg, Nelson, Rupprecht, Schultz*
4:00 — 4:15 Break  
4:15 — 5:00 How to Deal With a Difficult Opponent: A View from the Trenches Clark, Facciola*, Monheit, Weiner
5:00 — 6:00 Reception  
Time Session Panelists
  Wednesday, March 30, 2022 (all times EDT)  
12:00 — 1:15 Privilege: Breakout Session Entire Faculty
1:15 — 1:30 Break  
1:30 — 3:00 Privilege: Plenary Session Blaustein, Favro, Hughes*, Nolan
Time Session Panelists
  Thursday, March 31, 2022 (all times EDT)  
12:00 — 1:15 Social Media: Breakout Session Entire Faculty
1:15 — 1:30 Break  
1:30 — 3:00 Social Media: Plenary Session Jones, Keller*, McVoy, Peck
3:00 — 3:15 Break  
3:15 — 4:45 Rule 16(b) Case Management Conference: Plenary Session Johnson, J., Matthewman, J.*, Peck

*Panel Moderator