Extract from Kelly Twigger’s article “5 Advantages Of Having An ESI Protocol For Your Matter”
I am a big advocate of having an ESI protocol for every matter. Drafting an ESI protocol forces you to consider all of the discovery issues in your case at an early stage and provides for the protection of your client’s data during the discovery process.
I can see the look on your faces.
Non-believers have just rolled their eyes. When you don’t know what you don’t know, you think an ESI protocol is just another exercise that is not needed.