One of the first electronic discovery tasks you'll do for a case is to collect potentially responsive electronic documents from your client. Before you start that collection effort, you should prepare a data-gathering plan to ensure that you are covering all the bases. That plan should identify the locations from which data will be collected, who will collect the data, and a schedule for the collection effort.
Learn about Your Client
First, you need information from your client that is aimed at identifying all the possible locations and custodians of responsive data. Some of this information may be available in written form, and some is best gleaned by interviewing client employees.
Start by looking at:
• Organization charts to identify potential custodians.
• Organization charts for the IT and Records Management departments so you'll know what individuals have knowledge of the technology that is used and how and where data is stored.
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