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While it may seem self-evident, effective and continuous communication between the relevant stakeholders is a key aspect to successfully managing e-discovery in response to litigation. This is particularly true given the tasks that must be completed, the often short deadlines for completion of these tasks and the potential consequences of failing to comply with the e-discovery obligations under the Federal Rules. Although this principal applies to both plaintiffs and defendants, it can often be more important to defendants who received little or no advance notice of the impending lawsuit.

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