Todd Heffner

July 11, 2023 | Daily Report Online

This column is intended to remind practitioners of the relevant rules and suggests the right direction of ditching boilerplate objections, responding with the required specificity and avoiding the risk of waiving objections.

By Todd Heffner and Jim Calvert

5 minute read

September 06, 2022 | Daily Report Online

Pose the simple question: What would make you more likely to work from the office? Is it free food? (Maybe.) Raffle give-a-ways? (Definitely not.) A dunk tank to sink the managing partner? (Nailed it.) Everyone is different, and if you don't ask, you won't know what will make your remote workers want to show up.

By Todd Heffner and Matt Bailey

6 minute read

March 09, 2021 | Daily Report Online

You might not realize it, but ephemeral messaging has been around for some time (think self-destructing messages in "Mission Impossible").

By Todd Heffner

5 minute read

August 31, 2020 | Daily Report Online

Provide feedback to the document reviewers early and often.

By Todd Heffner

5 minute read

June 17, 2020 | Daily Report Online

If you're outside counsel and you've been hired because of the possibility of a future lawsuit, you need to seriously consider if your client's preservation obligations have already been triggered.

By Todd Heffner

5 minute read

April 07, 2020 | Daily Report Online

Near-dupe detection and email threading can greatly reduce the number of "duplicate" documents that must be reviewed.

By Todd Heffner

5 minute read

February 25, 2020 | Daily Report Online

The point of document review is not to review documents. The point of document review is to identify relevant documents for depositions, cross-examination, etc.

By Todd Heffner

5 minute read

January 30, 2020 | Daily Report Online

Discovery is grounded in reasonableness, not perfection.

By Todd Heffner

5 minute read

January 02, 2020 | Daily Report Online

If you cannot or should not look at every single document but still need to be confident all of the important documents have been found, Technology Assisted Review, or TAR, is a large part of the solution.

By Todd Heffner

5 minute read

January 02, 2020 | Daily Report Online

The first part of this two-part article on TAR covered why you should use it, what it is and some basics of how it works.

By Todd Heffner

5 minute read