Federal Rule of Civil Procedure 26(f) and Illinois Supreme Court Rule 218(a)(10) require attorneys to address e-discovery issues early in a case and consult with opposing counsel to craft a discovery plan. Here are 10 things for attorneys to consider when discussing e-discovery issues with the opposing counsel and the court. 1. Understand the extent of your client’s electronically stored information (ESI) and who possesses it. To adequately address e-discovery issues that may arise in a case, attorneys …