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At one time or another during a protracted and contentious discovery battle, we have all argued, somewhat sarcastically, that "what’s good for the goose is good for the gander." Now that we and, more importantly, our clients, have had ample time to experience the ever-increasing frustrations and costs associated with e-discovery, the goose and the gander should (finally) be able to agree on at least one thing: E-discovery can be incredibly burdensome, expensive, and a huge drain on resources regardless of which side of the proverbial "v." you are on. (In fact, the authors are offering their conclusions and recommendations based in part on their experiences responding to e-discovery requests and (mostly) working out disputes as each other’s adversary in a large commercial litigation.)

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