Does the answer depend on area of law or case complexity? Yes. In small matters with light ESI, simple terms, tight date ranges, and a straightforward production format can keep discovery neutral and affordable. In data heavy cases like employment, commercial, or class actions, we should plan for technology assisted review and validation so review stays within reach. In high risk or sensitive data matters, encryption and redaction planning need to start on day one so security does not become a bottleneck later. Across all of these, the judges' message is consistent. Cooperate early, tailor discovery to the issues, and use technology to reduce cost rather than inflate it (Association of Certified EDiscovery, 2019). add this as well