The Federal Rules of Civil Procedure require all parties to meet at the beginning of a case to talk about how to handle electronic discovery, and there are traps for the unwary.  Most notably, failing to request that electronic data be produced "in native format" allows your opponent to produce it any form reasonably kept in the ordinary course of business.  If only paper documents show up in response to your document requests, you won't have access to any of the "metadata" that can make electronically-stored documents so much more valuable as a discovery device than documents produced only in hard-copy form. 

Trying to fix such mistakes later can be quite costly, if it can be done at all.  In a recent case before the D.C. Federal District court, a magistrate judge imposed sanctions on both parties following a motion to compel production of e-mails in native format, stating, "two thousand dollars is not a bad price for the lesson that the courts have reached the limits of their patience with having to resolve electronic discovery controversies that are expensive, time-consuming, and so easily avoided by the lawyers' conferring with each other on such a fundamental question as the format of their productions of electronically stored information." 

The message is clear--formulate a specific plan for electronic discovery from the beginning of the case, and communicate your expectations to opposing counsel.