Jacksonville Attorneys Discuss New “Relevance and Proportionality” Standard


Jacksonville attorneys Jeffrey S. York and J. Morgan Foster published an article in the ACC North Florida Chapter’s Third Quarter 2018 newsletter.

In the article, titled “Three Years In: Has the New ‘Relevance and Proportionality’ Standard of Rule 26(b)(1) of the Federal Rules of Civil Procedure Changed the Landscape of Federal Court Discovery?,” they discuss changes implemented to Rule 26(b)(1) which now require that in addition to the requirement that discovery be relevant to any party’s claim or defense, it must also be “proportional to the needs of the case.” Six considerations are included for courts to apply to determine if the discovery is “proportional.” The article goes on to discuss cases where courts have applied the new rule since it became effective on December 1, 2015.

To read the full article, please click here.

About Jeffrey S. York

Jeffrey S. York is a partner in the Jacksonville office of Shutts & Bowen LLP, where he is a member of the Business Litigation practice group. Jeff has more than 20 years of experience handling complex business litigation matters for a vast array of corporate and individual clients. He is Martindale-Hubbell AV® rated and recognized as one of the Best Lawyers in America® in commercial litigation.  Jeff is licensed to practice in all state and federal courts in Florida and Georgia and the United States Courts of Appeals for the Eleventh Circuit and District of Columbia.

About J. Morgan Foster

J. Morgan Foster is an associate in the Jacksonville office of Shutts & Bowen, where she is part of the Business Litigation Practice Group. Morgan obtained her law degree from the Florida State University College of Law. She worked as a law clerk during her time in school, and participated in an externship with two Circuit Judges at the Second Judicial Circuit of Florida in Tallahassee. Morgan also participated as a Pupil member of the Chester Bedell American Inn of Court from 2014-2015.

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Shutts & Bowen, established in 1910, is a full-service business law firm with approximately 270 lawyers located in eight offices across Florida.

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