In Schreiber v. Schreiber [pdf], 2010 NY Slip Op 20271 (June 25, 2010), Judge Delores J. Thomas, denied the plaintiff’s request for a mirror image of her defendant lawyer/husband’s hard drive. The court denied the request without prejudice but noted should the plaintiff seek to renew her motion she must provided a detailed, step-by-step discovery protocol that would allow for the protection of privileged and private material. The court proposed a list of items the plaintiff should consider including a discovery referee, forensic computer expert, file analysis, scope of discovery, first-level review, second-level review, discovery dispute mechanism, cost-sharing, discovery deadlines, and the retention and disposal of the mirror image.