In S2 Automation LLC v. Micron Technology, Inc., No. 11-0884 (D.N.M. Aug. 9, 2012), the district court ordered the plaintiff to disclose to its opponent its electronic discovery “search strategy for identifying pertinent documents, including the procedures it used and how it interacted with its counsel to facilitate the production process.”  The court ordered that relief in response to statements by the plaintiff’s counsel, made during a discovery conference, that counsel had “delegated the process of gathering documents to [his client] and that he was generally unaware of the manner in which [his client] had provided the documents.”  The court held that Federal Rule of Civil Procedure 26(g)(1) requires a lawyer to make a “reasonable inquiry” before signing discovery responses, and that the details of the search strategy were required in order to assess whether plaintiff’s counsel had made such an inquiry.