One of the basic principles in eDiscovery process is that parties shall confer early in the discovery regarding the preservation and production of ESI when these matters are in issue in the litigation and seek to agree on the scope of each party’s rights and responsibilities. For this purpose, Chapter 24 discusses pre-trial meeting/conference and early exchange of computer system information. In pre-trial conference, the judge may make a scheduling order, amongst other things, to limit the amendment of pleadings. The scheduling order may include: (1) modifying the extent of discovery and (2) providing for disclosure or discovery of ESI including the form or forms in which it should be produced.