Jonathan D. Frieden and Leigh M. Murray, The Admissibility of Electronic Evidence Under the Federal Rules of Evidence, XVII Rich. J.L. & Tech. 5 (2011), http://jolt.richmond.edu/v17i2/article5.pdf.
…considering the significant costs associated with discovery of ESI, it makes little sense to go to all the bother and expense to get electronic information only to have it excluded from evidence or rejected from consideration during summary judgment because the proponent cannot lay a sufficient foundation to get it admitted.1
This paper drives home the point that how you start your case will determine how it ends.