Outten & Golden’s attorneys are experienced in deposing experts and corporate representatives relating to e-discovery issues in employment cases.  We can work with counsel to prepare for e-discovery depositions or we can actually conduct the depositions. We focus on technology and e-discovery so that the primary counsel can focus on the substantive legal issues.

Negotiations over the preservation and production of electronically stored information (ESI) can devolve into a stalemate situation, with the preserving or producing party claiming that the requesting party’s request would be unduly burdensome or costly. Before considering judicial intervention, the requesting party should obtain witness statements concerning the alleged burden and/or costs to bolster counsel’s representations. Depositions of information management systems personnel, technology experts, and vendors providing cost estimates may be necessary. These depositions can also establish what ESI is available and thus help shape the requesting party’s requests.