This is an ongoing problem, and often is not even thought about till it is to late. E-Discovery can expand rapidly, but it does need a path of possible evidence. Like someone saying in a deposition, he always texted me about those meetings or accounts. Many try and do a shot gun approach to E-Discovery and ask for anything and everything. In many cases a Judge will limit the reach of E-Discovery, unless it can be shown that an area may have pertinent information. There are basic E-Discovery training modules both in power point and you tube, that anyone can get a better idea of the problem.
from CTI Consulting http://ift.tt/2oInVFh