In e-discovery, function follows form. As a result of this truism, I've found that there is a correlation between the amount of experience an attorney has with e-discovery and the strength of his feelings about the form in which documents should be produced.

Let's put it this way: if I were a client, I wouldn't hire an attorney to handle e-discovery on a matter unless the attorney had a strong opinion about form of production—be it native, near-native, image files, or even (gasp!) paper.

The reason is that the form of production directly affects both the cost and the utility of the production. You can potentially save your clients significant amounts of money on e-discovery just by knowing which form of production will work best for your particular situation.