Many an organization waits until it has seen the corporate body on the table in a lawsuit or in a government proceeding before implementing an electronic-discovery preparedness program. Often, nothing short of an expensive, stressful litigation kluge is sufficiently compelling.

Doom and gloom predictions of the staggering costs of litigants’ collection, processing, review and exchange of terabytes of electronically stored information (ESI). Nor do war stories about night after night of waves of e-mails and electronic documents engulfing the electronic discovery (eDiscovery) process – and thus drowning a lawsuit before a judge or jury ever gets a chance to decide who, if anyone, wins the case.

So, without any guarantees other than “Do try this home,” . . . and, with apologies to David Letterman, . . . from the home office in Silicon Valley . . . in chronological order along the litigation timeline . . . drum roll, please . . . here are The eDiscovery Guru’s Top Ten Tips. . . .