It is possible to reduce ESI anxiety by effectively managing
electronic discovery: being proactive in defi ning the scope, understanding
preservation obligations and protections, and taking
reasonable steps calculated to protect potentially relevant information
Parties to a case
in a Michigan state court can (and should) proactively discuss
key ESI questions:
Will ESI come into play t • o a signifi cant degree?
• What ESI will be preserved?
• How will ESI be searched and what date, divisional,
organization, and geographic limitations will apply?
• How will ESI be produced?
• What, if anything, will be necessary to authenticate
ESI for trial?