Commit to a One-Page ESI Protocol
Commit to drafting an executable ESI protocol skeleton for one matter.
Draft a one-page ESI protocol skeleton for one active matter. Use the matter you will discuss at an upcoming Rule 26(f), meet-and-confer, subpoena response, or production planning meeting. By [date/time], I will draft a one-page ESI protocol skeleton for [matter] covering sources/custodians, production format, metadata, privilege/clawback, QC checks, and exception timing; I will send it to [reviewer] for comments. In 3 days, check whether the skeleton exists, was sent, and has at least one decision owner for unresolved format or privilege questions. A Rule 26(f) conference is scheduled and no ESI protocol draft exists. A subpoena response requires production format…
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