Although the start date of the new electronic-discovery procedural rules is still three months away, lawyers who haven’t sat down with clients to devise a plan may be losing a race against time.

The intent of the changes to the Federal Rules of Civil Procedure, effective on Dec. 1, is that they catch up with communications technology, which has turned matters of once-routine litigation into discovery nightmares as parties and courts grapple with electronic databases, e-mail, backup tapes and much more.

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