ELECTRONIC DISCOVERY

Friedemann Goldberg LLP offers eDiscovery litigation services as co-counsel with other law firms to assist in navigating the complexities of the eDiscovery process from start to finish to help achieve the best results, regardless of the size of the case.

The shift to a paperless environment has dramatically increased the quantity of potentially relevant information stored in electronic form and the number of locations and formats in which electronic data is maintained. The statutory inclusion of electronically stored information (“ESI”) in inspection demands has made eDiscovery a necessary and highly relevant aspect of litigation today.

We are a premier mid-sized law firm with offices in Sonoma County, Sacramento, and San Francisco. We provide excellent work product and quality litigation services to clients and co-counsel. Our eDiscovery litigation team is comprised of litigation attorneys, and a Litigation Support Manager who is certified as an E-Discovery Specialist by the Association of Certified E-Discovery Specialists (“ACEDS”), a BARBRI professional association.

Areas of Focus


Our services extend beyond matters of eDiscovery identified here to other aspects of the discovery process and general litigation matters.

Our services include:

  • all aspects of the meet and confer process
  • drafting discovery requests and responses
  • motion practice
  • protective orders
  • claw back agreements
  • ESI stipulations
  • and more


In-Review Data: Data stored on our eDiscovery software product during the “in-review” and “production” stages (collectively “In-Review Data”) will be charged a monthly fee at the In-Review Data rates (rates available upon request). Charges for In-Review Data are calculated by totaling the original file size of documents in-review and any saved productions, rather than the total data collected.



Parties must preserve potentially relevant information once litigation is reasonably anticipated. It is critical to identify all locations in which potentially relevant information may be stored, which may include but is not limited to desktops, laptops, handheld devices, email exchanges, shared network resources, cloud based computing, databases, hosted information, etc.

Our services include:

  • interviewing key personnel
  • issuing legal hold communications
  • identifying and preserving potentially relevant information
  • review, modification, and suspension of retention and deletion policies
  • follow up communications regarding preservation
  • documentation of preservation


Clients who self-collect data without experienced IT personnel and oversight by experienced counsel run the risk of insufficient collection, which may lead to sanctions. Our eDiscovery team can perform the collection independently or assist existing client IT or other personnel.

Our services include:

  • developing a collection strategy
  • collecting potentially relevant information
  • preserving the quality of data or metadata
  • tracking a chain of custody from initial collection to processing
  • documentation of collection


Once data is collected it will need to be initially processed and loaded into a suitable format for further processing, culling, review, and production. The culling of irrelevant data and filtering of data has the potential for a large cost savings to the client. Reducing the amount of data in review reduces hosting costs as well as the time needed to review documents for responsiveness and privilege.

Our services include:

  • preliminary analysis of data collected
  • processing of data into eDiscovery software
  • processing of native files and TIFF images
  • identifying technical errors
  • deNISTing - deduplication
  • culling of data
  • filtering data through the application of search terms


Generally, documents will need to be reviewed for responsiveness and privilege before production. You can conduct your own review using our eDiscovery software or we can conduct the review for you.

Our services include:

  • eDiscovery review software
  • team of experienced attorney reviewers
  • developing a coding structure
  • review and coding of documents for responsiveness, privilege, and other coding tags
  • remote reviewing and coding
  • creating data review sets for efficient reviewing
  • quality control review
  • redactions


The method and format of a document production should be determined at the outset of the discovery process to ensure that the form of production complies with discovery obligations and is in a format that can be used by the receiving party.

Our services include:

  • strategy and development of the form of production
  • creating document productions
  • transmitting document productions
  • quality control review of production
  • preparing privilege logs


Team Members

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Kyle Fisher has experience with a wide range of business matters, tax controversy matters, complex contracts, electronic discovery, and insurance disputes.

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John MacLeod is an associate attorney at Friedemann Goldberg LLP. His practice focuses primarily on litigation and e-Discovery matters. He has been with the firm since 2010.

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Michael Stuck is the Litigation Support Manager and Systems Administrator at Friedemann Goldberg LLP. He is a Certified E-Discovery Specialist through the Association of Certified E-Discovery Specialists (ACEDS). He has been with the firm since 2008.

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