As technology continues to evolve, organizations are increasingly facing challenges concerning whether, and to what extent, they allow employees to utilize their own devices for work purposes. When employees use their own personal, privately-owned devices to access, manage, and store organization information, organizations are frequently asked to produce information from those devices in litigation, which can impose significant costs on the employer. Whether such information is within the employer’s possession, custody, or control and whether that information is more readily available from other sources are frequent sources of disagreement.