In our last article we reminded readers that Federal Rule of Civil Procedure (FRCP 1) is the lodestar for eData lawyers, that directs parties and courts to use the rules to "secure the just, speedy and inexpensive determination of every action and proceeding." FRCP 1 does not simply suggest that we endeavor to be rational and practical during discovery, it demands it. We proposed to use our next series of articles as a refresher on the fundamentals of discovery and the importance of reasonableness that should guide practitioners and inform best practices in every aspect of a discovery, and Information Governance (or IG) practice. In that first article, we reviewed the fundamentals of data preservation for discovery and covered some legal-hold best practices.