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Looking back on my last few meet and confer sessions, I recall spending an inordinate amount of time discussing e-discovery processing and production specifications, and little on the location and description of electronically stored information (ESI). It is often the case that people feel more comfortable discussing the form and format of production details, however, it is critical to discuss the data map in detail. The best way to answer the two most often asked questions, “How much data is there, and how long will it take to produce?” is to ensure an up-to-date data map is in play.

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