COST

Analysis by Digital Discovery CLE Teaching Fellow Alexi Maltas

Cases

Anti-Monopoly, Inc. v. Hasbro, Inc. 1995 WL 649934, 1995 U.S. Dist. LEXIS 16355, S.D.N.Y., 1995.

Magistrate Judge Andrew Peck Good analysis of digital discovery issues. Plaintiff moved to compel Hasbro to disclose computer database notwithstanding that Hasbro had already disclosed a paper version. Court found that Plaintiff was certainly entitled to databases even though paper copies had been produced, and producing party can be required to design a computer program to extract the data from its computerized business records, subject to the Court's discretion as to the allocation of the costs of designing such a computer program. Court analyzed time and expense required to create such a database, found that potential benefit to plaintiff was speculative, and ordered parties to meet and discuss. When Plaintiff later moved to compel disclosure without having to pay for it, court held that Plaintiff would be required to pay expenses

Toledo Fair Hous. Ctr. v. Nationwide Mut. Ins. Co. 703 N.E.2d 340, Ohio Com.Pl., 1996.

African-American homeowners and prospective homeowners brought action against insurance company alleging that company engaged in "redlining" to avoid African American neighborhoods. Judge held that class status was warranted, and allowed discovery of insurance company's databases of documents regarding policy renewals and cancellations, financial information, marketing, info on redlining, and employee portfolios, but not on insurer's sales meetings or agent interactions. Defendant argued that discovery order was burdensome, predicting cost of more than $110,000, but judge says that they cannot avoid discovery just because their own record keeping system makes discovery burdensome. "If a party chooses to store information in a manner that tends to conceal rather than reveal, that party bears the burden of putting the information in a format useable by others." Insurance company ordered to pay costs of discovery.

In re Brand Name Prescription Drugs Antitrust Litigation 1995 WL 360526, N.D.Ill., 1995.

Class Plaintiffs moved to compel disclosure of Defendant CIBA-Geigy Corporation's inter-corporate emails. Defendant admitted emails are discoverable, but argued that request was overly broad, burdensome, and expensive, and therefore Plaintiff's should pay estimated $50,000-$70,000 to retrieve emails. Court found that expense was mainly due to Defendant's own record-keeping scheme. Court noted that at least four other defendant manufacturers had produced emails without requesting that Plaintiffs pay. Plaintiffs' motion granted.

Procter & Gamble Co. v. Haugen 179 F.R.D. 622, D.Utah, 1998.

P & G sued competitor and competitor's distributors for spreading rumors of P & G's Satanism, specifically alleging defamation, unfair competition, violations of Lanham act, Utah Truth in Advertising Act, etc. Judge Kimball dealt with various motions here, including sanctioning P&G for failing to preserve relevant emails, and allowed P&G to do a keyword search of Defendant's database on issues concerning agency or control in general, but limited search so that it would not yield general commercial or competitive information.

Articles

Delaney, Timothy Q. "E-mail discovery: The duties, danger and expense." Federal Lawyer 46 (January 1999) 42

Lacouture, Peter V. "Discovery and the use of computer-based information in litigation." Rhode Island Bar Journal 45 (December 1997), 9.

Grenig, Jay E. "Electronic discovery: Making your opponent's computer a vital part of your legal team." American Journal of Trial Advocacy 21 (Fall 1997), 293

Rubenstein, Bruce. "Electronic discovery costs are leveraging settlements." Corporate Legal Times 7 (September 1997), 26

The Linnen Story: Excerpts from Mundy, Alicia. "Dispensing with the Truth"