Backup tapes are sequential storage media created for disaster recovery, historically the archetype of not reasonably accessible data.

Discovery cost shifting requires the requesting party to bear some production expense where the burden is disproportionate.

The EDRM is the standard conceptual framework describing the stages of electronic discovery from information governance through presentation.

Electronic discovery is the process of identifying, preserving, collecting, reviewing, and producing electronically stored information in litigation.

Electronically stored information is any information created, stored, or communicated in digital form that is subject to discovery in litigation.

An ESI protocol is the parties' negotiated agreement governing how electronic discovery will be conducted, covering sources, search, format, metadata, and...

Information governance is the organizational program managing how data is created, retained, secured, and disposed of across its lifecycle.

Legacy system data resides in decommissioned or obsolete platforms requiring specialized effort to access.

Not reasonably accessible data is electronically stored information a party need not produce absent good cause because of undue burden or cost.

The Rule 26(f) conference is the early meeting where parties plan discovery, including how electronically stored information will be handled.

Two-tier discovery distinguishes reasonably accessible sources that must be searched from inaccessible sources requiring good cause.