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We have developed expertise serving as discovery referees/special masters in cases where the number of parties and/or the nature of the dispute will likely burden the Court’s limited resources.

In these situations, State and Federal judges often appoint a referee or special master to resolve discovery disputes, conduct in-camera reviews and otherwise assist the Court with tasks that would otherwise be handled by the Court and its staff.  The referee/special master is nominated by the parties to the lawsuit and they are responsible for paying his fees.  Among other things, a referee/special master:

  • attends depositions and rules on objections;
  • approves and enforces the terms of Protective Orders;
  • oversees the briefing of discovery motions, holds hearings on those motions, and issues written rulings;
  • conducts reviews of documents alleged to be privileged; and,
  • performs other tasks as instructed by the Court, including drafting Orders, periodically reporting to the Court on the status of the case, and otherwise assisting in case management.

We provide these services in all types of cases, including complex, multi-party cases involving trade secrets, business torts, patents and other intellectual property (copyright, trademark, etc.) matters.


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