"Attorneys should not agree to the use of predictive coding or other search methodology or protocol without thinking it through. Attorneys should develop and evaluate their electronic discovery protocol and evaluate the role of discovery technologies prior to meeting with the opposing party. The protocol should cover multiple areas including define the parameters they are willing to consider with regards to reliability, recall, and new technology. This protocol will assist the attorneys in ensuring that they know and can express what is acceptable to them prior to any agreement."