ESI Discovery Request Checklist for IP Cases

As IP counsel in [JURISDICTION], draft a detailed ESI discovery checklist for [OPPOSING_PARTY] in [PATENT/COPYRIGHT_TRADEMARK] litigation involving [TECHNOLOGY/BRAND]. Your checklist must: 1) Identify five key custodians with justification for each (e.g., "CTO for all source code revisions during [YEARS]"), 2) Specify precise date ranges covering [START_DATE] to [END_DATE] with possible extensions, 3) List eight file types including source code repositories, design files in [FORMATS], and emails containing [KEYWORDS] or [PHRASES], 4) Define required metadata fields (author, edit history, access logs), and 5) Include three proportionality arguments tailored to [JURISDICTION] rules. Present in a three-column table with Requested Item, Relevance Basis (citing specific allegations), and Expected Objections with counterarguments. Add "DRAFT - TAILOR TO CASE SPECIFICS" watermark and format for easy conversion to PDF. Include preservation instructions for cloud-based documents.