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.
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