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E-DISCOVERY5 MIN READ

Draft the ESI Protocol Skeleton

Create a practical ESI protocol outline for a civil matter.

A stale template must become a usable ESI protocol for a matter involving email, Slack, spreadsheets, and privilege risk. Make each clause executable by a person, tool, or deadline. The common trap is template comfort: broad phrases sound lawyerly but leave vendors and reviewers guessing. Name source scope List initial custodians, systems, date ranges, shared repositories, and a process for adding sources after interviews. The protocol should not pretend the first source list is final. Set production forms Define email image/text/load file, native spreadsheets, redaction handling, family rules, and placeholder slipsheets. Rule 34 usability depends on data type, not habit.…

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