Description
312716 v1 Appendix A DISCOVERY CHECKLIST1 1. Prepare a written litigation-hold and preservation letter to client upon receipt of matter. (Note: Because many courts hold that the duty to preserve attaches upon service of the complaint, you may already be behind the eight-ball here if the client has not already undertaken to impose a litigation hold so you must do this task immediately.) 2. In initial conversations with client, discuss the necessity of a litigation hold memorandum and preservation...

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