In this installment of our continuing series on e-discovery basics, we address the importance of developing a thorough understanding of client data and planning for discovery before litigation starts. In our last article, we discussed how an Information Governance program presents an opportunity for organizations to bring reasonableness to the discovery process, and we identified several practical components that should be incorporated into a records-retention program.

A common thread between Information Governance and the core phases of e-discovery—identification, preservation and collection of data—is the necessity for eData attorneys to develop a full understanding of the locations and sources of client data. Why is this important?  There are three good reasons.