First Name:
Last Name:
Email Address:
Company/Organization

Cost

1. Does the shifting environment of discovery from ink-on-paper to digital media advantage or disadvantage plaintiffs? Explain.

2. Would you consider contesting the request for deleted email on the grounds that it should not be discoverable? What about deleted email would take it out of the sphere of discoverable material?

3. Your discovery consultant says that 99% of the responsive data is likely to come from easily searchable active data, but that the last 1% will come from inactive data, for which the searching costs will be extremely high. Would you request limitation to active records, or in the alternative, shifting of the cost of electronic discovery to the plaintiffs for searching inactive records? How would you frame your request? How would you assess your prospects for success?