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For a number of years, many courts have been adopting “fast track” procedures, mandating that cases go to trial within one year of filing a lawsuit. See, e.g., Cal. Ct. Rules 208, 209 (employment litigation). For example, in the Eastern District of Texas, Judge Ward’s local rules have laid out strict guidelines and provide for early discovery deadlines. These early deadlines push cases forward and force parties to spend time, effort and money to quickly produce potentially relevant electronically stored information (ESI) for litigation. See, Appendix M Patent Rules, 3-3, 3-4 April 21, 2011.

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