Date: 2011-06-24 Docket: 08-CV-43188; 08-CV-43544  Master MacLeod. | Link

At para 35, the Master points out: "Even at the pleading stage parties should have an eye on what issues will be raised by the litigation and therefore what will be the scope of production and discovery.  It is then the responsibility of each party to understand who might be the potential custodians of relevant information and to understand its own information architecture.  Without a technical understanding of what information is stored and where it is located, it is difficult or impossible to estimate how long it will take to retrieve such information, what processes should be used and what cost might be involved."