Your Litigation Response Plan should include what I call the data universe, that is, the electronically stored information that's needed for your company to respond to litigation.

What email systems, voice mail systems, or document management systems, or document types are used at your company?  This should all be in the plan.

There are 183 billion email messages sent each day. That's 2 million email messages every minute. Now we know most of those are jokes, but there is some key data in emails and we need to find them.

Email is critically important in litigation. In fact, if you look across all cases, I would say that email is probably the most important data type. So it is important in your plan, to identify the email system(s) your company uses. Some companies use more than one email system because they have acquired other companies. Does your company use Microsoft Exchange, Lotus Notes, GroupWise, or CcMail, or other corporate email systems?  You need to know this and it needs to be in the plan.

Specify the protocols and strategies you will to use to extract mailboxes of an individual, group of individuals or just certain individual email messages from the email system. Also, remember discovery requests don't just involve email. If your company uses Microsoft Outlook, you know that items can be saved as contact items, calendar items, tasks, notes, and there are public folders if your company uses Microsoft Exchange. Specify in your Litigation Response Plan how you will respond to requests for contacts, calendars, tasks, and public folder items.