1. Litigation and eDiscovery
How to say NO to outrageous
preservation requests
Robert Levey
978-996-2758
robert.levey@catelas.com
www.catelas.com
Legal – What to preserve? Copyright © 2011 Catelas Inc. All rights reserved

2. Preservation Requests
Scenario: a Preservation Request
comes in from opposing counsel
Figuratively it looks
something like this…
• Way too broad
• Unreasonable
• Outrageous?
Your fear of the “unknown” takes over
You either comply with the request or settle
(to avoid the cost of discovery)
Legal – What to preserve? Copyright © 2011 Catelas Inc. All rights reserved

3. You need to say NO WAY!
Enough is enough…
You need to say NO WAY!
Legal – What to preserve? Copyright © 2011 Catelas Inc. All rights reserved

4. Introducing…..
Identification … WHO IS INVOLVED?
Pre-Case Intelligence …ONE STEP AHEAD
Legal – What to preserve? Copyright © 2011 Catelas Inc. All rights reserved

5. What we do
A defensible approach to defining a
reasonable scope of Preservation
1. Identify precisely
‘who is involved’ 3. Allowing you to reasonably
on Day 1 define the scope of
Preservation
4. Saving you millions in
Litigation Costs
2. Provide supporting 4
evidence to back up
‘what needs to be 2
preserved’
0
Before After Catelas
Legal – What to preserve? Copyright © 2011 Catelas Inc. All rights reserved

6. Thank You
Robert Levey
978-996-2758
robert.levey@catelas.com
www.catelas.com
Legal – What to preserve? Copyright © 2011 Catelas Inc. All rights reserved