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Corporate defendants, and especially their in-house counsel, shudder when the term electronic discovery or e-discovery is mentioned. Defendants have nightmares about complying with voluminous discovery requests from plaintiffs that target e-mails, databases, hard drives, servers and back-up files. E-discovery places the defendant on the defensive and hampers its ability to develop its defense strategy. It is time for defendants to turn the tables on plaintiffs and make e-discovery a two-way street by serving e-discovery requests on and conducting Internet searches of plaintiffs.

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