Most counsel underutilize the option of asking the court to appoint an independent forensic neutral. The default assumption is that party-retained experts will be sufficient. Sometimes they're not.
Practical signposts that suggest a neutral examination would be a better path:
Thin productions. When one party's productions appear materially incomplete and the other party cannot move forward without resolution, a neutral examination of the producing party's systems can establish what was preserved, what was collected, and what's been omitted.
Battle of the experts is producing more heat than light. When opposing forensic experts have reached fundamentally inconsistent conclusions from the same evidence, a neutral can provide a third interpretation the court can rely on.
Spoliation allegations are at issue. Whether evidence was preserved, altered, or destroyed is itself a question with significant litigation consequences. A neutral examination can establish the factual record on which the court bases its sanctions analysis.
Cross-border or specialized data sources are involved. Discovery touching foreign jurisdictions, specialized industry systems, or emerging technology platforms often benefits from neutral expert involvement that neither side has resourced.
Proportionality is genuinely contested. When the cost or burden of discovery is the dispute, a neutral's assessment carries more weight than partisan filings.
For counsel: requesting a neutral is not an admission of weakness. It's often the most efficient path through a discovery dispute that would otherwise consume months of motion practice.