Model Discovery Plan and Privilege Order
The Principle Development Subcommittee has developed a Model Discovery Plan and a Case Management Order (CMO) relating to privileged documents. The Committee has approved both the model Plan and the model CMO. The Model Discovery Plan helps the parties focus and articulate the scope of discovery, the form of production and review strategies for electronically stored information. The CMO provides a model Federal Rule of Evidence 502(d) order and some suggestions for the more efficient and effective logging of privileged documents.