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 technology. The need to provide systemic and institutionally-based assistance for defense attorneys, especially panel attorneys, in the area of e-discovery will con- tinue to grow. As sophisticated electronic devices become cheaper and hold more data, and as networks become faster, the sheer amount of e-discovery will continue to increase exponentially.1094 Unless steps are taken, ESI will negatively impact both the cost and the quality of indigent defense. •
 1094 Lookingatjustasingledevice,from2013to2015,theaveragemonthlydatausageofacellphone user increased from 269 MB to 804 MB. It is projected that average monthly cell phone data usage by the year 2021, however, will be 8.9 GB. See industry-survey (last visited January 6, 2017); 2021-gigabytes-erricson/ (last visited January 6, 2017).
No recommendation presented herein represents
the policy of the Judicial Conference of the United 2 0 1 7 R E P O R T O F T H E A D H O C C O M M I T T E E T O R E V I E W T H E C R I M I N A L J U S T I C E A C T 235
States unless approved by the Conference itself.

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