The Sedona Conference® “Jumpstart Outline”

Questions to Ask Your Client & Your Adversary to Prepare for Preservation, Rule 26 Obligations, Court Conferences & Requests for Production


From the Introduction:

This outline sets forth, by way of example only, a series of topics and questions to ask your client and your adversary as you prepare for meeting obligations related to preservation, requests for production, court conferences, and Fed. R. Civ. P. 26. The answers to these questions will guide you in (i) instructing your client about its preservation and production obligations and (ii) understanding your adversary’s systems and preservation efforts to date, and (iii) structuring and tailoring your discovery requests addressed to your adversary. This is a simplified outline to assist, in particular, those people who have had only limited experience in dealing with electronic discovery.”

Rules: Rule 26(f) of the Fed. R. Civ.


The full text can be downloaded at…