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Delaware’s Court of Chancery has broad power to expedite discovery for cases involving preliminary injunctions. The scope and timing of discovery in these high stakes commercial and corporate litigations are greatly compressed and can impose considerable burden on the parties. With expedited discovery, the Court encourages the prompt collection of “core documents” from “key custodians”. These key custodians may be board of directors members, corporate executives or their investment advisors. Their documents may be stored in a number of locations including on networks (email servers, SharePoint, network shares), personal devices (laptops, tablets, iPhone) or cloud-based mail (Yahoo, Gmail, Microsoft 365).

Parcels works with counsel to quickly identify, collect, process and review documents using search terms, date restrictions and advanced computer analytics. At the direction of counsel, we will prioritize the production of “core” and “significant” documents on a “rolling basis”. If the parties agree to a “quick peek” review, Parcels can provide productions in native, TIFF or PDF format.  We’ll coordinate with review teams and implement efficient workflows to meet the most demanding deadlines.

Our team has decades of experience handling expedited discovery cases and will help you address issues related to:

  • Alleviating burden to the parties
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    • Minutes of the relevant meetings of the board of directors and any board committees
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    • Working group lists associated with the transaction
    • Engagement agreements and fee arrangements with investment advisors
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  • Handling discovery of third parties, such as investment advisors and others with fiduciary responsibilities

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