Discovery of documents has changed, primarily because electronically stored information (or ESI) is dynamic and not static like paper documents; and it is more challenging to identify, preserve and collect. In this paper, the author outlines the step-by-step mechanics involved in the identification, preservation and collection stages of the e-discovery process.

A sample litigation hold notice (for provision to a client with an obligation to preserve relevant electronic documents) is attached.

This paper was presented at LESA’s Document Management in Complex Litigation Files program offered in February 2015.