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A successful corporate e-discovery readiness program requires more than efficient deployment of qualified people, process and products. Readiness is measured most practically in the corporation’s response to inspection, and the strength, resilience and confidence with which the next e-discovery “circus” is managed. Corporate counsel are the first line of defense against unreasonable discovery and are expected to pursue proportionate discovery to control costs. A robust e-discovery cost allocation program will leverage corporate e-discovery benchmarks and data profiles to support counsel’s response to unreasonable discovery demands with factual statements of the anticipated burden and expense of performance.

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