Here's a good ediscovery survival guide for corporate counsel:
1. Update and enforce your records management policies;
2. Adopt litigation early warnings strategies;
3. Implement detailed litigation hold;
4. Review your computer use policies with ediscovery in mind;
5. Educate your legal, administrative, and IT staff on the fundamentals of ediscovery;
6. Adopt collection plans for electronically stored information ("ESI");
7. Don't forget to consider all possible sources of ESI -- see here and here.
8. Designate an ediscovery liaison;
9. Monitor the ediscovery process;
10. Stay up to date on ediscovery issues.
Note: I added numbers 7 and 9 to the list discussed in the article hyperlinked above.
(Source: Smith, Arthur L., "United States: E-Discovery Survival Guide For Corporate Counsel," (Feburary 19, 2007).)
