Every week, the Array team reviews the latest news and analysis about the evolving field of...

Every week, the Array team reviews the latest news and analysis about the evolving field of eDiscovery to bring you the topics and trends you need to know. This week’s post covers the period of June 1-7. Here’s what’s happening.
On eDiscovery Today, Doug Austin writes about a Tennessee court in In re Realpage, Inc., Rental Software Antitrust Litigation that stepped in to enforce a stipulated TAR protocol—singling out defendant Sares Regis for failing to conduct a proper responsiveness review and ordering compliance within 12 days.
On March 7, 2025, the court ordered Sares Regis to produce documents responsive to Plaintiff’s RFPs by March 28, 2025 using the August 30, 2024 search terms. But after missing the deadline and a one-month extended deadline, Sares Regis proposed three shortcuts to the plaintiffs. Sares Regis would:
Plaintiffs objected, arguing those proposals bypassed responsiveness review as set out in the agreed-upon TAR protocol and improperly shifted the burden to them. Magistrate Judge Crenshaw agreed—emphasizing under Rule 34 that Sares Regis bears responsibility to review and produce responsive documents, not the plaintiffs.
Judge Crenshaw ruled in a May 28, 2025 filing that Sares Regis must:
Notably, the court gave the defendants discretion on how they were to meet this deadline by declining to compel additional review attorneys, but warned that noncompliance could bring sanctions.
Why it matters
Other recent eDiscovery news and headlines:
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