Almost every lawyer who has worked on written discovery in recent years has addressed issues arising from electronically stored information.The volume and nature of ESI, along with the cost to categorize, search and tender this type of data raises problems unlike those typically involved with the production of documents.The December 2016 Illinois Appellate Court opinion in Carlson v. Jerousek, 2016 IL. App (2d) 151248, addressed ESI and discovery in what, in essence, is a case of first impression.The Carlson plaintiff …