Hold and Data Preservation Notices

The 2021 edition of the Thomson Reuters Electronic Discovery and Records and Information Management Guide provides checklists for legal holds and preservation notices. It’s interesting to compare the recommendations in this textbook against the tips suggested by two Zapproved employees based on experience, which was discussed in last night’s tip.


Here are some tips left out last night:


- take steps to preserve native files and metadata.

- image a backup of any relevant digital media.

- don’t redeploy hardware which may contain relevant data.

- “Forbid forensically naive network administrators or other members of the information technology department from

checking out or otherwise investigating relevant devices.” Id. at 244.

- State the name of the case, the venue, and the causes of action

- state the business relationship between the requesting party and the company.

- instruct that the current retention schedule be suspended.