In November 2012, the U.S. District Court for the Northern District of California issued a new set of e-discovery guidelines.  In general, the guidelines require cooperation and open communication between counsel about topics such as what electronic information has been preserved and how it will be searched.  The court also issued a helpful checklist for the discussion of e-discovery topics between counsel in the Rule 26(f) process and a model e-discovery stipulation.  E-Discovery (ESI) Guidelines, http://www.cand.uscourts.gov/eDiscoveryGuidelines.