[Insert company logo]
Attorney Work Product
Privileged and Confidential
TO:
All Relevant Persons with Knowledge Including
[insert]
FROM:
[company] Legal Department
DATE:
[insert]
RE:
URGENT REMINDER – Preservation of Documents and Electronically Stored
Information
[Describe matter underlying hold] (the “Matter”).
Please be advised that we are legally required to retain and preserve and not delete or destroy all
documents, tangible items and electronically stored information, wherever located, that we
currently possess or control that contain information relating in any manner to the Matter
(hereinafter collectively referred to as "Documents" and "Electronically Stored Information"). This
notice is intended to encompass all such Documents and Electronically Stored Information
regardless of their format, and applies to originals and non-identical copies of the non-exclusive
list of materials listed below.
In considering what to preserve, you should use the broadest definition of "Document" and
"Electronically Stored Information" as possible, regardless of whether or not these items were
generated or received internally or externally, or whether these reside at the premises of
[company], or any other entity including any affiliated entity of [company], at your home, on any
other storage devices, on any wireless storage devices, or on any drive on any computer, smart
phone, or laptop you possess, have custody of, or control. Documents and Electronically Stored
Information to be preserved include, among other things, hard copies and electronic copies of the
following:
•
Correspondence, instant messages, text messages, email (whether sent or received),
tweets, and email attachments;
•
Internet postings and Internet blogs;
•
Memoranda, reports, spreadsheets, notes, drafts, work papers, contracts, agreements,
understandings, printouts, minutes, agenda, documents, summaries, writings, and other paper
files;
•
Calendars, logs, and diaries;
•
Presentations, charts, graphs, and brochures;
•
Drawings, photographs, images, and databases;
•
Phone records, voice mails, audio tapes, video tapes, films, sound recordings, facsimiles,
speeches, and research projects;
•
Media reports, magazines, and newspapers;
•
Other data or data compilations, stored in any medium from which information can be
obtained, including on mainframes, shared drives, optical images, microforms, and other
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electronic data including but not limited to personal computer drives, external hard drives,
server/network drives, databases, CDs, diskettes, DVDs, floppy disks, PDAs, smart phones,
home computers, tablets, laptops, voicemail, Zip-drives, flash/thumb/or any other type of external
or portable hard drives or flash drives, and disabled computer drives or systems;
•
Other tangible objects; and
•
Archived records.
Starting today and continuing every day until you are notified in writing by the [company] Legal
Department that this legal hold no longer applies, you must affirmatively save and not delete all
existing Documents and Electronically Stored Information.
Until further notice from the [company] Legal Department, this obligation to preserve supersedes
the standard Record Retention Policy and email retention policy of [company].
If there are others whom you reasonably believe may have Documents and Electronically Stored
Information, please email their names to [insert] immediately so that we may be sure that they
also receive a copy of this memorandum. This memorandum may be periodically updated and a
copy will be provided to you at such time.
Please call extension [insert] if you have any questions. Thank you for your assistance.
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