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ESI Protocol Insights Guide
A practical, battle-tested guide for drafting and negotiating ESI protocols — with templates you can use today.
What's inside
What is an ESI Protocol?
Understand what ESI protocols cover, when they are required, and how courts interpret them.
Drafting Checklist
A structured checklist of provisions every ESI protocol should address, from data sources to privilege logging.
Negotiation Tactics
How to approach opposing counsel, where to push back, and which battles are worth fighting.
Technology Considerations
Aligning your protocol with modern review tools — including keyword search, TAR, and communications data.
Sample Language & Templates
Ready-to-use language for common ESI protocol provisions, reviewed by experienced e-discovery counsel.
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