Your Litigation Response Plan should deal with strategies to handle the meet and confer effectively. The Federal Rules of Civil Procedure require that you negotiate e-discovery protocols with opposing counsel. So the Litigation Response Plan should include some checklists, forms, and protocols, as well as recommended methods of production. The plan should specify whether or not (or in what cases) a technical expert should assist in the meet and confer, and how you can increase the ease of obtaining approval for your case management order by the judge. Cases can be won or lost during this important stage.
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