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One of our observations after two decades of e-discovery practice is this: the move from a paper to electronic world hasn’t changed the fundamentals of discovery very much. Whatever its form, the data still has to be relevant, unique, not privileged and in the party’s possession, custody or control. That doesn’t mean that we can disregard some of the unique challenges electronic information presents, but upon reflection, it is clear to us that most questions that arise during discovery can still be answered by remembering these basic elements.

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