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Michael A. Fidelholtz
Controller, Form Tech Concrete Forms
Cleveland, Ohio

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6
The Document Trap

keyBe careful what you wish for.  In discovery, it is important you understand what you're asking for in your Requests for Production of Documents.  While it is absolutely true that Electronically Stored Information (ESI) is discoverable, there is a line of case law that one could find themselves having to answer to based upon their initial request.  Make sure your Requests get you the information you really want.

Download:
pdf the_document_trap.pdf