Litigation pits adverse parties against each other and is a way to settle disputes in court, but some litigants, and some lawyers, may be more adversarial than others. Indeed, the preamble to the ABA Model Rules of Professional Conduct explains that, as an advocate, "a lawyer zealously asserts the client's position under the rules of the adversary system." With the increase in data volumes and electronically stored information (ESI) discoverable in litigation, however, the Federal Rules of Civil Procedure explicitly instruct that lawyers also need to cooperate to secure the just, speedy, and inexpensive determination of every action. Notably, the committee notes on Rule 1 for the 2015 amendments to the Federal Rules state: "Effective advocacy is consistent with—and indeed depends upon—cooperative and proportional use of procedure." One area where zealous advocacy, cooperation, and proportionality are tested has been in determining when forensic examinations are necessary in e-discovery.