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While magistrate judges supervising electronic discovery often have their recommendations subjected to review by district court judges, the federal circuit courts of appeal are rarely a source of electronic discovery precedent. An exception is a recent opinion by the 2nd Circuit Court of Appeals in Chin v. Port Authority of New York & New Jersey, — F.3d —, 2012 WL 2760776 (2d Cir. July 10, 2012).