The Admissibility of Electronic Evidence Under the Federal Rules of Evidence

[v]ery little has been written . . . about what is required to insure that ESI obtained during discovery is admissible into evidence at trial . . . . This is unfortunate, because considering the significant costs associated with discovery of ESI, it makes little sense to go to all the bother and expense to get electronic information only to have it excluded from evidence or rejected from consideration during summary judgment because the proponent cannot lay a sufficient foundation to get it admitted.