Following the road to ESI preservation with three court questions The Zubulake court also answered “how must the duty to
preserve be met” by advising that litigants, or potential litigants
institute a litigation hold that insures the retention of all relevant
documents in existence when the duty to preserve evidence occurs as well
as any relevant documents that come into creation afterwards. Here are
some practical tips to ensure the timely and proper preservation of
documents include:
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