attorney client privilege

work product

DOCUMENT HOLD,PRESERVATION, AND

COLLECTION INTERVIEW CHECKLIST

Contact Information
Interviewee Name
Phone Number
Email Address
Title/Position / Hire Date
Department
Date of Interview
Persons Present
General
Have you received and reviewed the Litigation Hold Letter or Email regarding document preservation and retention in the ______matter? / Yes ____ No ___
Initial ______
Have you followed the directives and retained all documents referenced in the directives? / Yes ____ No ___
Initial ______
Have any such documents been lost, discarded or destroyed? / Yes ____ No ___
Initial ______
NOTES
Paper Documents
Where are responsive documents located?
Do you have any other responsive documents at your home, or at any location other than the office? Where?
Have you sent any responsive documents to a document archive? Identify location:
Client Computer
Desktop (Computer Name)/
Date Issued
Laptop (Computer Name)/
Date Issued
Email / Size Info
Have you created personal email stores (i.e. pst). If so, list the source computer and path for the email stores.
Identify any folders within Outlook that may contain files relevant to the matter. Please list complete file path
Do you access business email from any application other than Exchange/Outlook? If so, what application is used?
Have you created any personal backups of personal email stores; such as backup of pst files to a removable media or shared server?
Have you used any web-based email system(s) for business related communications? If so, identify application, user name and password.
Electronically Stored Information (ESI) / Size Info
Do you save files to the hard drive of the client computer (specify desktop or laptop)?
Identify any folders on your computer that may contain any files relevant to the matter. Please list complete file path.
Do you save files to a user allocated directory on a shared server? Identify any folders that may contain any files relevant to the matter. Please list complete file path.
Do you save files to a public location on a shared server? Identify any folders that may contain any files relevant to the matter. Please list complete file path.
Other Computers or Devices / Size Info
Has your computer been replaced within the past year? If so, do you (or the company) possess the old computer or any data extracted from that system?
Do you possess any other computer system(s) used for business purposes that has not been mentioned?
Do you store any business related files on your home computer (desktop or laptop)?
Identify any folders on home computers or storage media that may contain any files relevant to the matter. Please list complete file path.
Do you possess any other devices (i.e. iPhone, Droid, iPAD, SURFACE, etc.) on which you store business related files or text messages? If so, have you stored any files related to the matter on such devices?
Removable Media / Size Info
Do you save files to any removable media; i.e. floppy discs, CD, DVD, Thumb drive etc... (please list)?
Identify any removable media that may contain any files relevant to the matter.
Communication Systems / Size Info
Do you implement instant messaging for business purposes? If so, do you maintain any log files of communications?
Do you save any voicemail on the company phone system or via email? If so, identify location.
Third Party / Size Info
Do you store any business related files on a third-party service such as an Internet-based storage services or Application Service Provider (such as SalesForce.com)?
Databases / Size Info
Do you access or utilize any databases during the regular course of business? Please list.
Of these databases, please list all databases accessed by you relevant to the matter and identify any reports generated from those databases in the ordinary course of business for or by you.
General Electronic / Size Info
Have you experienced a technical breakdown (“Crash”) of any computers with which you have worked that may have contained relevant documents or data? Were any documents or data lost?
Have you sent any relevant documents to an electronic archive?
Can you think of any other places we should look for electronic documents belonging to you?

Who are other employees in the Company that, to the best of your knowledge, worked on the project or would have information relating to the project?

______

______

______

Verifications
Custodian / Date
RESEARCH DATA, Inc. / Date

Confidential – Subject To Attorney-Client Privilege/ Attorney Work Product

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