Electronic documents aren't automatically admissible just because they were produced to you by the other side. That's the message of a useful article in the National Law Journal: "Don't Let Your E-Evidence Get Trashed," by Jerold S. Solovy and Robert L. Byman.
Once you've assembled that stack of "hot documents," your job is only halfway done. Now it's time to start thinking about issues like authentication and hearsay.
In the quoted article, the authors mention a three-step approach: "seek a stipulation; barring that, propound a request for admission; and barring that, be prepared to establish authenticity and hearsay exceptions at trial."
In my own practice, I follow these steps but sometimes in a different order, sending the request for admission first. It's often once of the best ways to prod your busy opponent to start thinking about stipulations well in advance of trial.
I suggested a form for authenticating electronic documents in "Authenticating Exhibits Using Requests for Admissions: Two Methods." Look at the second method.
Related sections from my book Deposition Checklists and Strategies (for readers who own it):
1. §6:73 Practice Tip: Discovery of E-Mails
2. §6:76 Practice Tip: Admissibility of Employee E-Mails