There are some issues that could be a problem, including the spoliation of evidence. In the article Discovery of Portable Electronic Devices, 61 Ala. L. Rev. 193, 194 (2009), it has outlined that preservation of electronically stored information (ESI) can be difficult to store for a number of reasons. One reason is that it can be easily destroyed. It could be destroyed by accident or on purpose. An accident of destroying information would include but not limited to would be the destruction of a portable electronic device. If a client had information stored on their cell phone that is relevant to their case but is their only phone and their phone was dropped on the sidewalk and was shattered or was just dropped into the water and ruined, the evidence lost would be an accident. An example of purposely destroying evidence would be that either party purposely starts destroying evidence that could potentially help their case or hurt their case, such as forever deleting e-mails that pertain to the case. With the traditional discovery method, evidence could be better preserved because it would entail paper copies that could be stored in a file