---
title: "List the electronic-information points a federal discovery plan must state"
url: "https://ailawframework.com/obligations/incoming-evidence-deepfakes-and-synthetic-documents/list-the-points-to-agree-before-electronic-documents-are-exchanged-in-bu/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A44-FL20261022-12-US"
practice_area: "Incoming evidence — deepfakes & synthetic documents"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# List the electronic-information points a federal discovery plan must state

> List the matters a Rule 26(f) discovery plan must state the parties' views on, and mark the electronic-information items for the lawyer: changes to disclosures; subjects, timing, and phasing of discovery;…

Canonical page: https://ailawframework.com/obligations/incoming-evidence-deepfakes-and-synthetic-documents/list-the-points-to-agree-before-electronic-documents-are-exchanged-in-bu/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Incoming evidence — deepfakes & synthetic documents](https://ailawframework.com/obligations/incoming-evidence-deepfakes-and-synthetic-documents.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List the matters a Rule 26(f) discovery plan must state the parties' views on, and mark the electronic-information items for the lawyer: changes to disclosures; subjects, timing, and phasing of discovery; issues about disclosure, discovery, or preservation of electronically stored information, including the form or forms of production; privilege and trial-preparation claims, including any agreement to be put in an order under Evidence Rule 502; changes to discovery limits; and any other orders under Rule 26(c) or Rule 16(b) and (c). Record that a party need not provide electronically stored information from sources it identifies as not reasonably accessible because of undue burden or cost, unless the court orders discovery for good cause. Do not agree the plan. Do not draft the report. |
| What the lawyer must review | The lawyer agrees the plan. Rule 26(f)(2) requires the parties to confer, discuss preservation, and develop a proposed discovery plan, and to submit a written report within 14 days after the conference unless a local rule changes that timing. Rule 26(f)(3)(C) specifically requires views on electronically stored information, including the form or forms of production. Rule 26(b)(2)(B) addresses sources that are not reasonably accessible. The form that is produced still has to be met with evidence sufficient to support a finding that the item is what the proponent claims, under Rule 901(a). Rule 502 was not opened, so no privilege-order terms are supplied. The 14 days and the 21-day conference timing are not counted out to a calendar date. The tool does not draft the report. |
| Written for | United States |
| Applies to | [List the points to agree before electronic documents are exchanged in bulk](https://ailawframework.com/obligations/incoming-evidence-deepfakes-and-synthetic-documents/list-the-points-to-agree-before-electronic-documents-are-exchanged-in-bu.md) |

## Checking plan

- What the AI does: List the matters a Rule 26(f) discovery plan must state the parties' views on, and mark the electronic-information items for the lawyer: changes to disclosures; subjects, timing, and phasing of discovery; issues about disclosure, discovery, or preservation of electronically stored information, including the form or forms of production; privilege and trial-preparation claims, including any agreement to be put in an order under Evidence Rule 502; changes to discovery limits; and any other orders under Rule 26(c) or Rule 16(b) and (c). Record that a party need not provide electronically stored information from sources it identifies as not reasonably accessible because of undue burden or cost, unless the court orders discovery for good cause. Do not agree the plan. Do not draft the report.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- This is a federal civil discovery plan. It is not an Australian electronic-document protocol and it is not an immigration filing.
- Do not count the 21-day or 14-day periods into a calendar date. A local rule may shorten them.

## Sources

- [Federal Rule of Civil Procedure 26](https://www.law.cornell.edu/rules/frcp/rule_26) (checked 2026-10-22)
- [Federal Rule of Evidence 901](https://www.law.cornell.edu/rules/fre/rule_901) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*