Minding Your Business

Proskauer’s perspective on developments and trends in commercial litigation.

Stacey P. Eilbaum

Stacey P. Eilbaum


Stacey Eilbaum is an associate in the Litigation Department. Her practice involves a variety of complex commercial litigation matters, including securities litigation, cross-border commercial disputes, and insurance recovery.

Prior to joining Proskauer, Stacey served as a law clerk to the Honorable Ronnie Abrams of the U.S. District Court for the Southern District of New York.  At Cornell Law School, she was an Articles Editor for the Cornell Law Review, where she received the Herbert R. Reif Prize for skillful and lucid use of the English language in writing about the law for her Note,The Dual Face of the American Jury: The AntiAuthoritarian and AntiMajoritarian Hero and Villain in American Law and Legal Scholarship, 98 CORNELL L. REV. 711 (2013).

Subscribe to all posts by Stacey P. Eilbaum

First Department Finds Work-Product Protection Not Waived by Storage of Documents on Company Laptop

On June 6, 2017, the First Department had an opportunity to apply—and reaffirm—last month’s decision in Peerenboom v. Marvel Entm’t, LLC, where the Court held that use of a company email system for personal purposes “does not, standing alone, constitute a waiver of attorney work product protections” even if the user lacked reasonable assurance of … Continue Reading

Amended Rule 34: No Boilerplate Objections, but Specificity Remains a Question

Amended in December alongside many other rules in the Federal Rules of Civil Procedure, Rule 34(b)(2)(B) now requires that objections to document requests be stated with “specificity.” The early applications of the amended rule demonstrate that boilerplate objections will not stand, but courts have yet to answer more nuanced questions regarding the level of specificity … Continue Reading