Bilek v. Nat'l Cong. of Emp'rs, Inc.

1 Citing case

  1. Cary v. Ne. Ill. Reg'l Commuter R.R. Corp.

    No. 19 C 3014 (N.D. Ill. Feb. 22, 2021)

    See Federal Rule of Civil Procedure 26 Adv. Cmt. Notes, 2015 Amendment ("Framing intelligent requests for electronically stored information . . . may require detailed information about another party's information systems and other information resources.). See also Bilek v. National Congress of Employers, Inc., 2021 WL 25543, at *6 (N.D. Ill. Jan. 4, 2021); The Case for Cooperation, 10 Sedona Conf. J. 339, 344 (2009) ("Indeed, because knowledge of the producing party's data is usually asymmetrical, it is possible that refusing to "aid" opposing counsel in designing an appropriate search protocol that the party holding the data knows will produce responsive documents could be tantamount to concealing relevant evidence."). It may be that, at the end of a more fulsome meet and confer process, Defendant's email data will be the primary or even the only data source that needs to be searched for relevant ESI in this case.