In any proceeding, the parties should ensure
that steps taken in the discovery process are proportionate, taking into
account (i) the nature and scope of the litigation, including the importance
and complexity of the issues, interest and amounts at stake; (ii) the relevance
of the available electronically stored information; (iii) its importance to the
court’s adjudication in a given case; and (iv) the costs, burden and delay that
may be imposed on the parties to deal with electronically stored information.