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Chief U.S. Magistrate Judge Paul W. Grimm, Dist. Ct. Md., has suggested a low-tech way to lower the costs and burden of electronic discovery: Adopt the checklist used by prominent litigator Stephen D. Susman, of Susman Godfrey. The checklist is a list of suggested pretrial agreements that Susman proposes to opposing counsel. In light of the incredible cost of pre-production review of e-discovery, one of the most significant may be the “5 x 5″ proposal:

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