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Producing electronically stored information (ESI) has unfortunately become one of the most expensive tasks in litigation. Typically, parties comply with obligations to produce ESI by identifying the witnesses most likely to possess relevant documents and files, creating forensic images of their stored ESI from computer hard drives and shared servers, and then using Boolean search terms to identify the electronic documents that may be relevant. Finally, armies of junior associates and contract attorneys review the culled set of documents for responsiveness and privilege. Depending on the number of witnesses and the volume of their files, this process often involves searching hundreds of gigabytes of data, and may cost the producing party tens or even hundreds of thousands of dollars.

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