When I first started practicing, “document production” meant exchanging boxes filled with pieces of paper. But the world has changed. And so have the Federal Rules. You can no longer blow off the Rule 26(f) conference and then expect a magistrate judge to blithely accept an Alphonse-Gaston routine.
According to Judge Scheindlin, it is gross negligence for a lawyer not to send off a written hold letter to the client at the start of litigation. You are doing that, right? Along with the necessary follow-up letters?
One word: Qualcomm.
Let me know if I can help. For example, one task on your litigation to-do list should be to interview all “key persons” concerning all possible sources of ESI. I can do the legwork for you so that there are no unpleasant surprises later, e.g., a home laptop with important information.