Fred stated/asked:

So, perhaps they did NOT "understand how ESI is generated and ...."? 
 
And how common would be that shortcoming in the general business and legal
communities? 

I would think if you were the Counsel for an organization like Google, you
would be a bit more "hip" to this stuff- or you would make it the
responsibility of someone in your practice group to dig into finding out, as
Dave Macaulay says "The Way Things Work" http://goo.gl/seoFY 

Given all the changes related to production during discovery in the FRCP
took place in 2006, and have continued to be amended until 2010... there has
been plenty of opportunity to get your arms around an ESI Data Map for an
organization and if you have to defend a company as huge as Google, you
should be all over this.

Larry
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