Scenario A large pharmaceutical company recalls a product after serious safety-related concerns are raised. The company subsequently is faced with multiple lawsuits in state courts throughout the country. In-house counsel anticipates that plaintiffs’ counsel will propound broad discovery requests seeking, among other things, electronically stored information (“ESI”) from multiple custodians located in numerous e-mail accounts, databases and back-up tapes. In-house counsel is concerned with the prospect of complying with the e-discovery rules in each of these state courts.

Downloads –