Practice point: A court may establish the method and scope of electronic discovery, pursuant to 22 NYCRR 202.12 [c][3].
Student note: CPLR 3111 and 3122(d) require the requesting party to defray the reasonable production expenses of a nonparty.
Case: Tener v. Cremer , NY 1st Dept. 2011 ).
Tomorrow’s issue: Labor Law.
