information stored electronically, Including writings, drawings, graphs, charts, photographs, sound recordings, images, and Other data or data compilations—stored in any medium from which information can be Obtained either directly or, if necessary, after translation by the responding party into a Reasonably usable form. Potentially Discoverable - Any items, including documents, tangible things, or ESI, that May fall within the scope of discovery in a particular lawsuit under the Federal Rules…
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