Salient points are:
- Hammer out a phased discovery plan— Agree to limit initial collection efforts to the key custodians so that if initial efforts do not get what is needed, then a new, expanded phase of discovery can begin. This limits the scope of discovery without handcuffing parties later.
- Limit the number of custodians — Not everyone involved in a given case will have a smoking gun email. Each custodian removed from the list can save time and expense in collecting data.
- Limit the search terms — Too many search terms or terms that are too broad will produce too much ESI to process and review.