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Meanwhile, in this case, the DOJ has simply requested documents from Doe, a request which he has decided to challenge in federal court, as is his right.

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It may be appropriate for the parties to retain thirdparty neutral experts in some cases with unusual or complex technical issues, or other ediscovery challenges, such as search of large disorganized collections of ESI.

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The court limited the exemption to records prepared as a result of the inmate being in jail and noted that the statute does not limit the exemption to records only in the possession of the jail.

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