Ode to E-Discovery in 2009 (With Apologies to William Shakespeare)

We did it last year for two thousand and eight:
A review of the year’s e-discovery “greats.”
Here’s a more recent summary wholly in rhyme
To get you all up-to-date on two thousand and nine.

As a whole, common themes have begun to emerge,
Due to problems that have spurred many judges to urge
More cooperation and much earlier e-discovery plans,
And clarity on native-metadata versus PDF scans.
Numerous sanctions resulted, the courts raising their swords
Of adverse inference, default judgment and monetary awards.

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