Just settling upon an agreed list of queries with your adversary may not assure a meeting of the minds, when it comes to documents found through e-discovery. The parties must be clear about the disposition of items hit by queries. Do those agreed searches serve as a de facto request for production, with the documents being "responsive per se"? There is ambiguity here, and reasonable minds can disagree.
Are Keywords Just Filters?
New Jersey Law Journal
June 6, 2013
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