When preparing the Litigation Response Plan, you should include a list of all departments at the company, employees, custodians and witnesses that are often involved in litigation. Human Resources has this information. You should include an organizational chart as an exhibit to Litigation Response Plan.

Over time, you will learn how to map departments and individuals to certain types of litigation. When a complaint is served on the company, based on the legal theories and claims made, you can immediately determine what individuals are involved as custodian and witnesses, and what department(s) must be contacted.

See the diagram below.