2. Ten Things Every Corporate Legal Dept
Should Know about Discovery
1. Create and maintain appropriate
document retention policies and
practices
3. Ten Things Every Corporate Legal Dept
Should Know about Discovery
2. Utilize an effective ESI archiving system
that permits efficient search, review, and
culling of ESI as well as immediate
placement of litigation holds
4. Ten Things Every Corporate Legal Dept
Should Know about Discovery
3. Understand the company’s data
infrastructure and develop a data map
5. Ten Things Every Corporate Legal Dept
Should Know about Discovery
4. Establish an ESI team to develop and
implement a litigation action plan
6. Ten Things Every Corporate Legal Dept
Should Know about Discovery
5. Educate employees and enforce
compliance with retention policies and
practices
7. Ten Things Every Corporate Legal Dept
Should Know about Discovery
6. Avoid delegating record retrieval and
review to outside vendors
8. Ten Things Every Corporate Legal Dept
Should Know about Discovery
7. Hire outside counsel who are
knowledgeable about ESI discovery and
who are technologically savvy
9. Ten Things Every Corporate Legal Dept
Should Know about Discovery
8. Develop appropriate trigger points for
anticipating litigation and develop
litigation hold procedures to implement
such triggers
10. Ten Things Every Corporate Legal Dept
Should Know about Discovery
9. Take proactive steps to prevent the
potential inadvertent production of
privileged records
11. Ten Things Every Corporate Legal Dept
Should Know about Discovery
10.Determine what information is not
reasonably accessible up front and take
steps to defend that position when
necessary
12. Speaker Contact
William F. Savarino
Cohen Mohr LLP
1055 Thomas Jefferson Street, N.W.
Suite 504
Washington, D.C. 20007
(202) 342-2550
bsavarino@cohenmohr.com