Jumpstart the eDiscovery Process

If you're looking for a checklist to use when meeting with a client in order to prepare for ESI discovery in advance of a FRCP 26(f) meet and confer, or in response to requests for productions, use Appendix A to the Sedona Conference Cooperation Guidance for Litigators & In-House Counsel, the 'Jumpstart Outline'. It's a list of questions to ask about Document Retention Policies; Key Custodians of Potentially Relevant Information; Network Servers; Email Servers; Hard Drives; and Non-Company Computers with respect to data preservation and production obligations. See:

https://thesedonaconference.org/system/files/sites/sedona.civicactions.net/files/private/drupal/filesys/publications/Cooperation_Guidance_for_Litigators_and_In_House_Counsel.pdf