In fact, the defendants were unable to commit to any specific
ESI production deadline, as they had yet to solve the problem of their client's proprietary Korean email system.
His services have ranged from drafting or modification of Corporate Information & Records Management Policies; counseling regarding specific document retention
deadlines, statutes of limitation, and governing regulations; preparation of litigation hold notices to data custodian interviews and preservation plan preparation; data collection planning; preparation for and attendance at Rule 26 (f) meet and confer sessions; and data processing and
production of
ESI in response to discovery requests.