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There is a significant industry based on e-discovery that never sees, or requires actual paper. Much more likely is an inhalation of the contents of a custodian's hard drive, or the ingestion of a full PST file (MS Outlook email form) into a system, or downloading email inboxes from Office 365 or Gmail.

Once ingested, the documents are searched for words or phrases, tagged as relevant, privileged, or non-responsive. See the FRCP (Federal Rules of Civil Procedure) for discussion of electronic documents in discovery.

Not only are courts expecting parties in lawsuits to supply documents in electronic form, there are are now rules in some courts tailored to TAR, or technical assisted review, which often means LSA (Latent Semantic Analysis).

So the idea of dropping tons of paper on the hapless opponent is an idea that is practically of antiquity, dating back to the MCI/ATT lawsuits. Large lawsuits simply don't work that way anymore.




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