A new District of Columbia decision shows how a documented preservation program still produced sanctions, fee-shifting, and adverse jury argument — and why the same reasoning lands harder when the data is text messages, Slack, and Teams instead of email.
Case: United States ex rel. Staggers v. Medtronic, Inc., No. 15-cv-392 (TSC/GMH) Court: District of Columbia | Decision: April 6, 2026 | Judge: United States Magistrate Judge G. Michael Harvey
By Kelly Twigger
Podcast | Transcript
A word of warning — this one is longer than our usual posts, but definitely worth the read. Grab a beverage and dive in.
The five-year stay that turned a routine migration into a sanctions order
This case is one I want every litigator who advises corporate clients to read carefully. You’ve seen the rough outline of this fact pattern before, but the way it plays out in this decision is going to be quoted in spoliation motions for years.
A False Claims Act qui tam suit is filed in 2015 and served in August 2016. Within weeks, the defendant places more than 300 custodians on legal hold and is doing what every sophisticated information governance program is supposed to do. Documented process. Suspended retention policy on flagged accounts. A written escalation path for additions. Two months after service, the Court stays discovery on a motion to dismiss. That stay holds for more than five years, until late December 2021.
While the litigation is paused, the defendant’s IT team runs a planned enterprise project that has nothing to do with the case. The company has used Enterprise Vault since 2007 to archive corporate email, and by 2013 it is holding more than a billion records. After Medtronic adopts a two-year retention policy in 2013, it starts migrating the archive to Microsoft Exchange Server 2013 in May 2015. The migration runs through 2017. Enterprise Vault is decommissioned in February 2021, and from that point on, the new system’s retention policy and the legal hold infrastructure determine which records survive.
When discovery resumes at the end of 2021 and counsel finally runs broad searches, twenty custodians have partial or total data loss. Some were never added to the hold. Some were added late. Several were on the hold for one matter, came off when that matter resolved, and were then quietly stripped of their older data when the two-year retention policy started running again, all before this case got around to adding them. The legacy archive that could have backstopped any of this is gone.
Plaintiffs brought a motion for sanctions for spoliation, and United States Magistrate Judge G. Michael Harvey issued his ruling on April 6, 2026. The opinion is long and factually detailed, with custodian-by-custodian analysis across fourteen disputed people. But the framework it lays out applies far beyond Medtronic and far beyond email. With text messages, Slack, Teams, and every other collaboration platform now generating most of the ESI in your cases, you are going to see this reasoning tested over and over again in data sources that are far harder to preserve cleanly than email ever was.
Case of the Week
Preservation is two questions, not one
Here is the doctrinal point I want you to internalize from this opinion, because it is the most important one. The court does not evaluate preservation as a single yes-or-no question. It evaluates two things separately. First, was the migration process reasonable, meaning the system-level decisions about how to move a billion records? Second, were the hold-timing decisions for individual custodians reasonable? Those are different questions, with potentially different answers.
That framing does real work. A reasonable enterprise preservation system, fully documented and executed in good faith, does not protect you from unreasonable custodian-level decisions inside that system. Medtronic survived the first analysis and lost the second, which is how a documented preservation program still ends up paying a fee award and facing an adverse jury argument at trial.
Why the migration was reasonable
The Court found Medtronic’s handling of the migration reasonable, and the way it got there is worth understanding if you defend similar transitions. The Court grounded its analysis in the Sedona Principles, Third Edition, which the District of D.C. and most other federal courts treat as authoritative. The principle that did the work in this opinion is one United States District Judge Shira Scheindlin established in the Zubulake decisions in the early 2000s and courts have applied consistently in the two decades since: “perfection in preserving all relevant electronically stored information is often impossible.” Reasonable steps are required, not heroic ones.
What made the migration reasonable, in the Court’s view, was not the outcome (which was clearly imperfect) but the existence and execution of a documented plan. The defense could point to specific operational decisions. It executed a full data copy from Enterprise Vault to Exchange for every custodian on legal hold, regardless of the two-year retention horizon that would otherwise have applied. It built a lookback process for custodians missed by the initial migration. And when it realized that routine IT deletion of former-employee accounts was creating preservation gaps, it built a reconstruction process to recapture data from those accounts. None of those processes worked flawlessly. The lookback ran only intermittently and was discontinued in October 2020. The reconstruction effort depended on coordination across several internal teams that did not always communicate well. But the question for the Court was not whether the program worked perfectly. The question was whether it existed, whether it was executed in good faith, and whether the people running it had the expertise to do so. On all three counts, the defense cleared the bar.
The Court drew the contrast with two cases the Relators relied on. In In re Petters Co., a bank decommissioned its Lotus Notes archive while subject to a preliminary injunction prohibiting destruction and made no real effort to preserve relevant material before destroying the backup tapes that contained it. In Est. of Moreno v. Corr. Healthcare, the defendant sent a single email to outside counsel about open cases, placed a hold on one named individual, deleted everything else, and the CIO later testified that one purpose of the retention policy was so that “bad emails” would be destroyed. The Court called those efforts lackluster. Medtronic’s, even with all its imperfections, was not.
The standard the Court articulates is the one you want to remember as your spoliation practice moves into newer data sources: “the mere fact that relevant data was lost does not mean that the party holding such data failed to take reasonable steps to preserve it.” That language is going to do a substantial amount of work in the next several years as litigation involving text messages, ephemeral chat, and collaboration tools tests how much loss is acceptable when complete preservation is operationally difficult. But the principle protects only parties who can produce documentation of what they actually did. If you cannot put a written preservation plan in front of a magistrate judge, you cannot invoke this reasoning. The absence of documentation will not be cured by your representation at the hearing that reasonable steps were taken.
What managing one of these migrations actually looks like
Let me shed some light on what an Enterprise Vault to Exchange migration looks like from the inside, because the operational difficulty of what the Court is evaluating in Staggers is easy to underestimate. I managed the same transition for a client from 2009 through 2012. The scale was about a third of what Medtronic faced in terms of data volumes and custodians, but it was still considerable and took months. The period over which we were still releasing data tied to closed legal holds ran more than six years after the migration itself was complete.
The fundamental problem with Enterprise Vault, which many parties stood up in the early 2000’s following the Zubulake decisions, was that data could not be exported from the system in a clean way. The system was designed for search and retrieval, not for back-end migration. Every preservation request had to be executed by running a front-end search, narrowing by date range and custodian, and then extracting the resulting records to a separate location. So during the migration, for every custodian relevant to active or anticipated litigation, we manually identified the relevant date range for each matter on which that person was a custodian and pulled the data accordingly. When the same custodian appeared on multiple holds, we did the work separately for each one, because each matter could then be released independently and the data tied to a released matter had to be deletable without affecting data still needed for another matter.
The decision we made with the client was to manage the preserved data outside of the new Exchange environment entirely. We built a separate, indexed storage repository organized by custodian and by matter. We treated Exchange as a production system, not a preservation system. When a matter resolved and the hold was released, we could delete the specific subset of preserved data tied to that matter without exposing data still needed for any other open matter on the same person. That separation is what protected the client. If we had trusted the new Exchange environment, with its operational retention policies and its Active Directory flags, to remember the legal preservation context of every record it inherited, we would have ended up in the same position Medtronic ended up in, and probably for the same reasons.
A few practical observations from that experience that you should take into the next migration you advise on. First, this kind of work could now be handled much more efficiently with technology, (including AI) than it could in 2009, or in the 2015 to 2021 window Medtronic was operating in. What took us six years of careful spreadsheet bookkeeping could be done in a fraction of that time with the right tools today. But the technology does not replace the documentation discipline. It accelerates it. If you do not know what you have and what you need to preserve, no system is going to fill the gap for you.
Second, this work requires a discovery counsel in the room with IT. On every matter where I serve as discovery counsel for a corporate client, my function is to be the liaison between the legal team and the IT team. I attend the meetings where IT decisions are made and translate those decisions into preservation consequences before they happen, rather than after. This is not a role outside trial counsel can play from a distance, and it is not a role in-house IT teams will recognize the need for on their own. Without someone in that bridge position, the fact pattern in Staggers repeats. IT does what IT does. Legal hears about it years later. The data is gone. If you are managing multiple aspects of litigation for a corporate client, you need someone in the mix at that client who understands what is happening to their data and what decisions IT is making that might impact preservation.
Third, watch for the strategic use of spoliation motions in cases that have weak merits. I have had matters where a legacy database was referenced in emails produced five years after the underlying events, was not actually relevant to anything material in the case, but was leveraged by opposing counsel into a sanctions motion designed to manufacture leverage on the merits. The only defense against that play is real-time documentation of what your client has, what your client does not have, and why. Staggers is going to make these motions more common, not less, because it gives plaintiffs’ counsel a clearer roadmap for how to construct one. Do not fall into the trap.
Where the defense actually lost: hold timing on nine custodians
Now let’s talk about the part of the case where the defense lost the motion. The Court accepted nine of the fourteen custodians the Relators identified as having been added to the hold too late. The five it rejected were Health Economics Managers (HEMs) added in mid-2019, which the Court found to be a reasonable response time after the Relators served revised RFPs in May of that year asking specifically about Medicare reimbursement. So when the defense was actually put on notice that a category of personnel was relevant, it acted within a reasonable window. The problem was with the other nine, and the failures broke into three distinct patterns. You should pressure-test your own hold program against all three this quarter.
Pattern one: name confusion
Two HEMs who should have been added in May 2019 along with the five the Court accepted as timely were not. Mike Neal was added more than three years later, in August 2022. William Paul Harris was never added at all because of a simple and not uncommon problem – defense counsel said it had confused William Paul Harris with a different employee, Paul T. Harris, a sales manager who had been on the hold since 2020. The Court was unsparing: “A sophisticated enterprise like Medtronic, with tens of thousands of employees and tens of thousands on legal holds, should have processes in place to prevent confusion about employees with similar names, perhaps especially when the names are common, like ‘Harris.'”
That is a brutal standard, and it is a pretty large system-wide process to put in place. But that is the bar. So here is what that process actually has to look like in practice if you want to meet it. First, your legal hold database needs to capture more than name. At a minimum, it needs to capture employee ID, current and prior job titles, department, and email address, so that every custodian is uniquely identifiable. Second, every time a new name is added, the administrator needs to confirm the unique identifier against the source document that prompted the hold, whether that is the complaint, the relevant RFP, a witness list, or an internal communication. Confirm against the source, not against memory. Third, build a same-surname flag. When you add a Harris, a Smith, or another common surname to the hold, your system needs to surface every other employee with that surname and force the administrator to make a deliberate choice. If you cannot produce those three steps in writing, you cannot tell a court you had a process that reasonably addresses the problem that beat Medtronic here.
Two further practical notes on this issue. Name changes during the life of a hold are a recurring source of preservation gaps that come up in nearly every long-running matter. Custodians get married. They get divorced. They rebrand their professional identities. The email address you are preserving against on day one may not be the address generating responsive material a year later. Your hold workflow has to track name changes against employee IDs and account histories, not just against the email address you happened to capture when the hold was issued. And that work has to happen at the moment of addition, not at the moment of production. By the time you are running searches against your hold list, the time to correct an identification error has often already passed.
Pattern two: “we didn’t realize until later”
The second pattern involves five Support Link custodians, marketing director (later Vice President and General Manager) Cindy Kent, and medical education manager Annette Mittelmark. All of them were added to the hold years late. The defense’s explanation was that it did not appreciate their relevance to the case until later sets of RFPs spelled it out. The Court rejected that explanation by going back to the discovery requests themselves. The Relators served their initial RFPs in October 2016, and those requests specifically asked for documents relating to “instructions, advice, and/or information provided to … SupportLink Representatives” and “[a]ll documents sufficient to identify … Medtronic SupportLink Representatives.” The revised set of RFPs served in May 2019 included the same requests. The second set served in May 2022 also included the same requests. The defense’s argument that May 2022 was the operative notice date, but May 2019 and October 2016 were not, was untenable on the face of the discovery record.
This is the part of the opinion I expect to see quoted in spoliation motions for the next several years, because it gives you an unusually clean argument against the “we didn’t realize at the time” defense. The Court’s question is direct: why was the same request sufficient to put the defendant on notice in 2022 but not in 2016? The defense had no answer. The next time you are on the receiving end of “we didn’t realize until later” from opposing counsel, pull the original RFPs. If the request was the same, the notice was the same.
What this means for you in practice is that your initial custodian list cannot be built off a quick read of the complaint and a generic intake interview. You have to build it off a careful, category-by-category cross-reference between the operative pleading and every set of discovery requests served at any time. And you have to revisit it every time new requests come in. The custodian list is not a static document. It is iterative, and the duty to expand it continues throughout the life of the case. Know who has left the company. Know what IT initiatives are underway that might impact data availability. Know what new categories of information are surfacing through discovery. When opposing counsel adds custodians late in their own preservation conduct, this decision gives you the argument that they were on notice years earlier. That argument cuts both ways, so the only protection against having it cut against you is rigorous attention to the discovery record from the very beginning.
Pattern three: the silent destruction of dropped holds
The third pattern is the one with the deepest operational consequences, because it is the one most likely to be replicated in any enterprise environment that combines a routine retention policy with a portfolio of overlapping legal holds. Several of the impacted custodians here had been on legal holds for other matters. While those holds were active, the two-year retention policy was suspended for those custodians’ data, and the data sat in Microsoft Exchange undisturbed. When those holds were released because the underlying matters resolved, the retention policy started running again on a rolling basis, and the data was deleted as it aged past the two-year horizon. By the time the Relators identified those custodians and Medtronic added them to the hold in this case, the data was gone from Exchange. The lookback to Enterprise Vault either was not triggered (because the system reported the mailbox had been migrated) or could not be completed (because Enterprise Vault had been decommissioned in February 2021).
The destruction was silent in the sense that no system flagged the loss as it was happening. The hold release ran through the standard workflow. The retention policy did what it was designed to do. The mailbox status reports continued to show that preservation had occurred correctly. It was only when broad searches were finally run in August 2021 that the gaps became visible, and by then it was too late to recover anything.
If you are running an enterprise retention policy, here is what you need to do. Evaluate every hold release against the full portfolio of active and reasonably anticipated matters, not just against the matter that is closing. Before the retention clock restarts on a custodian whose hold is being released, someone needs to confirm that no other open or foreseeable case has any plausible interest in that custodian’s records. The review has to happen on a regular cadence, with documented sign-off at each step. When did the attorney approve the release? When was the release notice distributed? When was the data actually deleted? When I managed this process for the client I mentioned earlier, we revisited the hold structure quarterly. If a matter resolved during that quarter, in between our scheduled reviews, we took immediate steps to evaluate whether the data needed to be kept for any other matter. Someone has to be managing that process continuously, and they have to be documenting it as they go.
And during any period when discovery is stayed in a major matter, this review needs to happen more frequently, not less, because the discovery stay produces exactly the conditions under which silent destruction proliferates. Custodians leave the company. Systems get decommissioned. Other holds drop. Your legal team feels that the case is paused, but the data destruction continues on its normal schedule. A discovery stay is a danger zone for preservation failures. Over-invest. Do not coast.
Whether the lost ESI could be restored or replaced
Rule 37(e) does not authorize sanctions if the lost ESI can be restored or replaced through additional discovery, and this element of the analysis gets glossed over way too often. Medtronic put a serious effort into defeating the motion on this ground, and it is worth understanding how that effort played out so you can make a better one if you ever find yourself defending a similar motion.
The defense ran reverse searches across every other preserved custodian for emails in which the impacted custodians appeared in the To, From, CC, or BCC fields, or within the body text. It recovered tens of thousands of records, including 124,026 of Cindy Kent’s roughly 189,000 destroyed emails, 67,181 of Annette Langer’s 160,000, and 42,181 of Mittelmark’s 112,000, along with similar percentages for the other impacted custodians. That was a great call on the defense’s part, even though it did not ultimately defeat the element.
The Court’s holding on this element is important because it tells you how much recovery is enough. Quoting Hollis v. CEVA Logistics U.S., Inc. from the Northern District of Illinois, with emphasis from the original opinion preserved, the Court held: “The question is whether the electronically stored information can be restored or replaced,” not whether the moving party could obtain similar information by “obtaining statements from witnesses.” Deposition testimony does not substitute for missing ESI, even if it covers the same factual territory. The burden of demonstrating irretrievability sits with the moving party, but the standard for clearing that burden is not as high as you might assume. Citing Borum v. Brentwood Vill. LLC from this same district, the Court found that where “at least some responsive emails were likely irremediably lost” and the moving party cannot “fully recover” them, the irretrievability threshold is cleared. Many thousands of emails remained unaccounted for after Medtronic’s reverse searches were complete, and that gap was enough.
So if you are defending a spoliation motion, run the reverse searches anyway, even understanding that the recovery is unlikely to defeat the motion entirely. Every record you recover reduces your prejudice exposure on the back end of the analysis, and the effort itself helps distinguish your client’s conduct from the kind of indifference that supports a finding of intent to deprive. Reconstruction is meaningful harm reduction, not a complete defense. A defendant who does not undertake it is making a worse record than necessary on every subsequent element of the Rule 37(e) inquiry.
Why the Court did not find intent to deprive, and why the next case may be different
The most severe sanctions under Rule 37(e), including adverse inference instructions and dismissal, are available only on a finding that the spoliating party acted with intent to deprive the moving party of the information’s use in the litigation. The Court did not make that finding here. Citing Hollis again, the Court held that where conduct can be adequately attributed to incompetence, courts should not infer malice. And more directly: “the failure to institute a legal hold is generally insufficient to support a finding of intent to deprive.”
That is a stringent standard, and it is consistent with how the District of D.C. and most other courts have applied Rule 37(e)(2) since the 2015 amendments. But I want you to put Medtronic’s outcome on this element next to several recent decisions where courts have found intent, because the contrast matters. In Nagy v. Outback Steakhouse, the District of New Jersey found intent through selective preservation of video footage. The Court outright rejected the incompetence defense the restaurant tried to mount. In Jones v. Riot Hosp. Grp. LLC, which we covered on Episode 135, the Ninth Circuit upheld a finding of intent based entirely on circumstantial evidence: missing text messages from the critical period that the plaintiff could not explain and could not produce. And in Skanska USA Civil Se. v. Bagelheads, which we covered on Episode 107, the Eleventh Circuit framed intent as “the willful destruction of evidence with the purpose of avoiding its discovery by an adverse party.”
So why no intent in Medtronic? Two reasons I can see. First, the defense’s misstatements and morphing explanations were attributed to incompetence and miscommunication, not to a scheme. Second, and this is the important point I want you to take with you, the Relators did not put forward evidence that the defendant forgot to put certain custodians on hold because those custodians’ data was bad for the company.
That second point begs a question. What happens in the next case when a plaintiff CAN show that a party strategically left key custodians off the hold because their data was unfavorable? Nothing in this decision forecloses that argument. And arguably, the Outback, Riot Hospitality, and Skanska lines of authority suggest a court would reach an intent finding in that situation if the plaintiff can demonstrate the pattern. So if you are on the moving side and you suspect strategic exclusion, look at who was added to the hold, who was left off, and whether the gaps correlate with seniority, proximity to the alleged misconduct, or damaging facts that surfaced through other channels in your case. If you can show that pattern, this decision is not your obstacle.
For defense counsel, the same point cuts the other way. Assume opposing counsel is studying your custodian list for those patterns right now. Your hold decisions need to be defensible not just on their merits but on their pattern. And that requires rigorous contemporaneous documentation of why each custodian was added or not added at the time the decision was made, not after-the-fact rationalization at the sanctions stage.
Prejudice and the requirement of specific evidence
Even where a court declines to find intent to deprive, it can still order curative measures under Rule 37(e)(1) on a finding of prejudice. The court did that here, but only for six of the nine impacted custodians, and the reason it limited the prejudice finding is the part I want you to sit with carefully, because it gets to a principle we talk about constantly on Case of the Week. You have to prove prejudice custodian by custodian, with documents, not with arguments.
The standard for prejudice under (e)(1) is “some proof” that the lost ESI would likely have been favorable to the moving party. The Relators met that standard for six custodians by producing specific artifacts from other parts of the production. A 2012 email from a senior HEM about voiding diaries and prior authorization documentation. A 2012 internal email about sales representatives coercing patients with marginal test results into implant procedures. The 2014 Support Link script known as “Warm Intake,” which directed call center agents to record patients’ feelings about their progress alongside the objective data. Those documents gave the court a concrete basis for inferring what the lost emails would likely have contained.
For the other three custodians (Haben, Medlo, and Mittelmark), the Relators did not produce comparable evidence. The court found no prejudice as to those three. Not because the legal hold problem was different, but because the proof was different. Same case, same theory, same factual pattern, same hold failure, different result. The difference was the documentary record the Relators put before the court.
This is the practical reality of how courts evaluate spoliation motions, and it puts a premium on the evidentiary work you do at every stage of the litigation. Generic prejudice arguments do not carry these motions. Specific, document-backed prejudice arguments do, and you have to develop the document support custodian by custodian, issue by issue. If you are moving for spoliation, treat the prejudice showing as a discrete evidentiary exercise, not as something that follows automatically from the spoliation finding. If you are defending, recognize that even your strongest arguments against intent may not save you from curative measures when the moving party has the documentary support to anchor the prejudice analysis.
Where the financial exposure actually lives
The court’s curative remedy here lets the Relators present evidence and argument to the factfinder about the loss of ESI from the six custodians as to whom prejudice was found. That is a common (e)(1) curative measure in the language of the Advisory Committee notes, and it is the kind of remedy most spoliation orders reach when intent is not found. But it is also a structurally limited remedy. Less than 1% of federal civil cases reach a jury, so the practical impact of the measure depends entirely on whether your case ever gets there. For most defendants on the receiving end of a curative measure like this one, the answer is that it probably will not matter.
The fee award is a different story, and it is where the real financial exposure lives. The scope is broader than most defense budgets anticipate. The court’s order shifts fees in three distinct categories. First, the Relators’ fees and costs in conducting discovery INTO the spoliation, which includes preparing for and taking the depositions that established the factual basis for the motion. Second, the cost of litigating the sanctions motion itself, including all briefing and argument. Third, the cost of litigating the amount of the fee award if the parties cannot resolve it themselves, which courts call “fees on fees.” The court signaled that the total amount will be reduced to reflect the Relators’ limited success, but the scope of the categories is the point. A sanctions motion at this scale costs the defending side tens of thousands of dollars to defend in its own right. Add paying the moving party’s investigation and motion costs on top, and you are looking at meaningful financial exposure running in parallel with the substantive sanctions risk itself.
So when you are deciding whether to litigate a hold-timing dispute, here is the spread you are wagering. Hold-timing disputes are best resolved at the meet-and-confer, before either side has committed serious resources to motion practice. By the time you are at the sanctions stage, the math has already moved against you. And if you are pursuing fees on a spoliation motion, the operational practice I would recommend is to track your spoliation-related time entries in real time, with a clear marker (I use “spoliation:” at the front of the time narrative) so the work can be filtered and proved when the bill of costs comes due.
What to do this quarter
Read this opinion as a prompt to audit your own hold program against the three failure patterns the court identified. Your audit should include a line-by-line cross-reference of your active custodian list against every operative pleading and every set of RFPs across your active docket, with a specific look at whether any category of personnel mentioned in any of those documents is currently uncovered by the hold. It should include a structural review of your legal hold database to confirm that it captures employee ID, job title, department, and email address (not just name) for every custodian, and that it surfaces same-surname matches on every new addition. It should include a mapping of your enterprise retention policies against the portfolio of released holds over the past several years, to identify any custodian whose data may have been deleted under the retention policy while still being potentially relevant to a different matter that opened later. And it should include a documented preservation plan for every active matter, meaning the kind of file you can produce to a magistrate judge as evidence of reasonable steps if the question ever comes up.
If you have matters that are currently on a discovery stay, do this audit more frequently and more thoroughly, because the conditions that produced the Staggers fact pattern are most acute during stays. Custodians leave. Systems get decommissioned. Retention policies continue to run. And your natural inclination is to monitor less actively because the case feels paused. The case is paused. The data destruction is not. Courts will not credit a defense that treats the stay as an excuse for reduced vigilance.
Finally, build the discovery counsel function into your client relationships if it is not already there. Most outside firms do not currently staff this role at their major corporate clients, but every enterprise running an active migration or retention initiative without that bridge in place is generating the next Staggers fact pattern right now. Someone has to be in the room when IT makes decisions about retention, migration, and decommissioning. Someone has to translate those decisions into preservation consequences before they happen, rather than after. If you have clients you are managing multiple aspects of litigation for, your firm needs to have someone in the mix at that client who understands what is happening to the data and what decisions IT is making that might impact preservation.
This decision is available on the Minerva26 platform with full issue tagging. If you’re a litigator navigating discovery strategy and want to stay ahead of decisions like this one, visit Minerva26.com to learn more or schedule a demo. Every decision covered on Case of the Week is searchable by issue, jurisdiction, and judge.
If it’s about the discovery of ESI, it’s covered in Minerva26, your discovery strategy platform.
- 📩 Get the newsletter
- 🎧 Listen to Meet and Confer
- 🔁 Share this post on LinkedIn
