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With the impending changes in the federal rules related to electronic discovery, opposing parties will be required to discuss any and all discovery issues involving electronically stored information (ESI).

In this context, discussions will likely focus on what information will be examined (e-mail, electronic documents, Web mail, instant messages), where this information is stored (computer hard drives, “ghost images,” backup servers), whether it is reasonable or unduly burdensome to access and review all potentially relevant information, and how the information will be produced.

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