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Certainly it’s smart to prepare for electronic data discovery — to be “proactive” about electronically stored information, and implement early case assessment systems and strategies. But sometimes the lawsuit’s the first sign of trouble, and you have to choose which fires to fight — and fast.

Don’t be paralyzed by fear of failure or confusion about where to begin. There are no perfect EDD efforts. Before the ESI experts arrive, there are things you can and must do. Here’s a quick compendium:

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