Your Litigation Response Plan should establish electronic discovery strategies to use in your cases. Develop these strategies and protocols holistically across all cases that you handle at your corporation. There will be modifications and exceptions for certain cases, but don't rethink your strategies in every case. If you have a list of e-discovery strategies and protocols, it reduces your mistakes and risks. Here is a short list of strategies to include in your Litigation Response Plan:  data sampling, preview of electronic data before sending it to electronic discovery vendors, cost shifting issues, scope of e-discovery, how to authenticate documents and files, search terms to be used, de-duplication techniques, and using one vendor as a neutral vendor to be used on both sides of the case. These are only a few examples that should be included in your Litigation Response Plan.

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