Put a litigation hold in place

Preserve every email, chat and file the moment a dispute is likely.

1. Write down what triggered the hold and when
2. Name every custodian who may hold relevant data
3. Map where their data lives: email, chat, phones, shared drives
4. Draft the legal hold notice (General counsel signs off)
5. Send the notice and collect every acknowledgement
6. Switch off auto-delete in email and chat for the custodians. Most people forget this: Retention rules keep deleting quietly unless IT turns them off
7. Keep the laptops and accounts of anyone who leaves. Most people forget this: A leaver's wiped laptop is the most common spoliation finding
8. Send a reminder to custodians every quarter
9. Log every step taken, with dates
10. Release the hold in writing when the matter ends (General counsel signs off)

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