From Bow Tie Law’s Blog:
In a case management hearing, the parties were directed to consider the following electronically stored information (ESI) issues at their Rule 26(f) conference for drafting their proposed Rule 16(b) order:
With regard to any discoverable electronically stored information (ESI) the parties may have, the Court further requests that the joint discovery plan also include any issues and concerns related to the following:
a. What ESI is available and where it resides;
b. Ease/difficulty and cost of producing information;
c. Schedule and format of production;
d. Preservation of information; and
e. Agreements about privilege or work-product protection.
Wallace v. Tindall, 2009 U.S. Dist. LEXIS 89669, *2-3 (W.D. Mo. Sept. 29, 2009).

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