This is a good check list for preparing for your discovery conference with the other side or simply preparing for litigation in general. The six factors detailed in the article are:
- Preserve Relevant ESI – author provides a case example
- Confer with your Opponent – describes importance and practicality of the meet n confer, also provides tips
- Collect Data Intelligently – it is no longer acceptable practice to do this yourself, at a minimum, meaningful supervision is required
- Rely on your Vendor – but be careful not to over delegate to the point that you don’t know what’s going with your project
- Consider using Hosted Databases – there are lots of reasons this is a good idea, probably the best one being that it provides a predictable cost for your budget plan
- If all else Fails, Go to Court – ediscovery project management best practices will hopefully help everyone avoid this scenario and the Sedona Conference’s Cooperation Proclamation strongly discourages discovery disputes but we know that that will happen in some cases so it’s best to be prepared
You’ll find many other checklists for discovery preparation on the internet. This article provides recent case law examples as reference points.