Federal Rule #26 is always Interesting on disclosure.
"Federal Rule of Civil Procedure Rule 26 was amended in 1993 to require the disclosure of related case materials without awaiting a discovery request. In the 2000 case Kleiner v. Burns the court interpreted Rule 26 to include backup media, and even deleted files." - "2028 - A Dystopian Story" By Jack Ganssle.
“Do I Really Have To Do That?” Rule 26(a)(1) Disclosures and Electronic Information:
https://scholarship.richmond.edu/cgi/viewcontent.cgi?referer...
Rule 26. Duty to Disclose; General Provisions Governing Discovery: