This is why the identification and preservation steps of the e-discovery workflow are so important as well as providing thorough Initial Disclosures under FRCP 26(a) and supplementing them later under FRCP 37(c) if new ESI is discovered.

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https://thetmca.com/federal-magistrate-judge-tells-cautionary-tale-about-how-not-to-conduct-discovery-in-federal-court/