E-Discovery Litigation Forms and Checklists

[ESI Attorney]

I thought it might be a good idea to put together a list of e-discovery forms and checklists available on the internet. As e-discovery attorneys, having a library of useful ESI forms and checklists could save us a lot of time.

Checklist for the Initial FRCP Rule 26(f) "Meet and Confer" Session
Use this list to ensure you have done everything to prepare for a Rule 26(f) Meet and Confer session. This checklist helps track the important steps in preparing for the Meet and Confer.

30(b)(6) Deposition Outline - Custodian of Electronic Records
Use this outline to prepare for a deposition with the custodian of ESI. This annotated outline lists a number of great questions along with comments to guide an attorney.

[NN Attorney]

Here is a good sample interrogatory form: E-discovery Sample Interrogatories

E-Discovery Guides

Although not checklists or forms, these guides are very useful to litigation attorneys.

One of the most important e-discovery guides is Managing Discovery of Electronic Information: A Pocket Guide for Judges.

The Sedona Conference publishes a number of excellent e-discovery guides available for free download: Sedona Conference Publications.

Here is a useful guidebook for e-discovery by Craig Ball: EDD Practical Plaintiffs Guide

LexisNexis offers a nice e-discovery guide, which is available for download after registration here: The Discovery Book: a handy desk reference for Federal Rules, key e-discovery cases, and best practices.

Finally, check out the Guidelines For State Trial Courts Regarding Discovery of Electronically-Stored Information.