D. Minn. E-Discovery Checklist
The United States District Court for the District of Minnesota has published a guide on its site list issues surrounding the production of ESI to be discussed at a 26(f) conference. See: http://www.mnd.uscourts.gov/FORMS/Clerks_Office/eDiscovery-Guide.pdf .
Amongst many other things, the Guide suggests that the burden of a litigation hold can relieved by limiting the number or types of custodians. It lists cloud storage repositories as an ESI source that can excluded because the burden of preservation outweighs the likelihood that information can be obtained from itthat is not retrievable from more accessible sources.
It recommends considering a 30(b)(6) deposition to delineate ESI requests. Database production can be handled by granting access to an opposing party's expert.
It raises the possibility that the parties share a joint translator for foreign language documents. The testing, sampling and auditing of keywords is recommended. It also suggests that the parties share information about their review and culling methodology in order to verify their processes.
The guide lists quick peek reviews as an option.