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In 2009, the American College of Trial Lawyers published a report by a task force on discovery. The overall conclusion was that discovery was destroying the civil judicial process: It costs too much, and can become an end in itself. The report stated that the electronic discovery process needed a serious overhaul. It included a comment from an attorney that the electronic discovery process is "a nightmare." That was in 2009. Nightmare is a mild description in 2013.

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