Sample Document Hold Notice

• Author: Judson W. Starr/Amy J. McMaster/John F. Cooney/Joseph G. (Jerry) Block/David G. Dickman
• Pages: 459-459

Page 459

Sample Litigation Hold Notice

To: [ALL RE LEVANT X XXXX X EMPLOYEES]

From: XX XXXX X, Company Counsel

Re: Notice to Pre serve and Retain Certai n Records

Date: July X, 20XX

Please be advised that XXXX XX recently received a gra nd jury subpoena issue d by the U.S. District Cour t

for the XXXX X Dist rict of XX XXX requesting the production of certa in categorie s of documents related to

____________________.

In light of the subpoena, XX XXX has a duty to preserve and mainta in certain documents, records and electroni-

cally stored informat ion (“ESI”), as more fully describe d below. Until further written notice f rom me, XX XXX and

its employees must take a ll reasonable steps to preserve all doc uments, records and ESI that is or may rea sonably be

considered relevant to the followin g categories:

1.

2.

3.

4.

All XXX XX personnel must preser ve and n ot discard, destroy, modif y or delete any documents and electronically

stored info rmation in your possession, custody, or control, in whatever form they now exist, that relate to the categories

listed above.

Electronical ly stored information includes, but is not limited to, all initial, interim, draft , and nal versions of the

following: e-ma il, voice mail, and other electronic communications (e.g., logged IM ); databa ses (e.g., Access, SQL,

Exchange, e tc.); digitized images; database spreads heets (e.g., Excel, etc .); word processing docu ments; PowerPoint®

slides and presentations; computerize d calendars and personal information ma nager (PIM) or personal digital as sis-

tant (PDA) in formation; internet usage, telephone, and network ac cess logs; billin g, accounting, or ledger entries;

web sites and web pages; and all similar data that is stored on, utilized on, or transmitted via a computer or computer

network, including the I nternet. ESI als o includes metadata, which is informat ion about a particu lar record or data

set which d escribes how, when and by whom it was collected, created, accessed, modied and how it is formatted.

All ha rdware and storage media containing such elect ronically stored information must be preser ved, regardless of

whether duplicates of the informat ion exist on other hardw are, systems, or platforms.

Going forward, plea se apply the same instructions in t his Memorandum to any documents created in the future

that relate to any of the categorie s listed above.

Please be certain to err on the side of preservation, and to promptly raise any quest ions or concerns you may have

about this Memorandum or your preservation obligations by contacting Company counsel in this matter, XXX XXX

(phone number) or XXX XXXX X (phone number). ank you for your cooperation.