Under the new Rules, parties must not only be prepared to swiftly produce the ESI they expect to use, but they must also, very early on, be fluent and forthcoming about their preservation of ESI and issues relating to its disclosure or discovery.  Amended Rule 26(f) requires that parties meet and confer shortly after the response date to address any issues relating to ESI, including its preservation and the form or forms in which it should be produced. The courts expect the conferees to arrive with answers and exert a genuine, good faith effort to resolve eDiscovery questions. LTC can prepare you for these meetings and accompany you to help in the communication with developing a workable plan with your adversary.