Question: Answer the question below by writing one paragraph: ESI Protocols: Plaintiffs propose a broad keyword search list including patient names and internal terms like flagged

Answer the question below by writing one paragraph:

ESI Protocols: Plaintiffs propose a broad keyword search list including patient names and internal terms like "flagged account," which may return thousands of irrelevant results.

What ESI protocol provisions should be proposed to address data volume, relevance, and privacy concerns?

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