Federal Judge Shira Scheindlin, author of the landmark series of e-discovery opinions in Zubulake v. UBS Warburg, has issued another missive on e-discovery that she opens with the famous yet ominous quote “[t]hose who cannot remember the past are condemned to repeat it.”
Scheindlin, who sits on the of the U.S. District Court for the Southern District of New York, entered the 85-page amended opinion in Pension Committee of University of Montreal Pension Plan v. Banc of America Securities on Jan. 15. Notably, she titled it “Zubulake Revisited: Six Years Later.” The original opinion was issue on Jan. 11.
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