This guide takes a proactive approach to discovery of electronically stored information. Proper planning in advance of possible discovery can greatly reduce the costs and burden of complying with discovery requests. Thus, initial emphasis is given to records management, which is important for both plaintiffs and defendants. This guide also recognizes that issues relating to the discovery of electronically stored information arise in state and federal court, as well as in administrative proceedings. While specific references are made to the 2006 amendments to the Federal Rules of Civil Procedure, the discussion in this guide includes state and federal courts.