Six years after penning her influential electronic discovery opinions in Zubulake v. UBS Warburg, Judge Shira A. Scheindlin of the Southern District of New York has revisited her guidance in Pension Committee of the University of Montreal Pension Plan v. Banc of America Securities (Pension Committee), which she dubbed “Zubulake Revisited: Six Years Later.”1

Judge Scheindlin is a recognized jurist and scholar in the area of e-discovery, and her Zubulake decisions have contributed greatly to the development of both federal and state jurisprudence in this area of the law. Her most recent word on e-discovery thus deserves careful attention, as it will likely shape the standard for compliance with preservation and production obligations within the Southern District of New York, the New York state courts, and beyond.

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