In many litigations, the need to properly structure a discovery protocol is often overlooked despite the fact that it is an essential element in the proceeding. (A protocol is a set of conventions governing the treatment, and especially the formatting, of data in an electronic communications system.)

By not making the proper requests to the other parties in a litigation, you can be denied valuable data. You will also fall short of meeting the e-discovery obligations as spelled out in FRCP 26(f).