eDiscovery

Legal Discovery Resource

Streamline your eDiscovery document collection with our comprehensive checklist of essential documents and evidence to request. Perfect for attorneys, paralegals, and legal professionals to ensure complete discovery and avoid missing critical evidence in litigation.

Key Benefits

Ensure complete document collection
Avoid missing critical evidence
Standardize discovery requests
Comply with discovery rules
Improve case preparation

Common Use Cases

Civil litigation discoveryCriminal case preparationRegulatory investigationsEmployment law casesContract disputesPersonal injury litigation

Frequently Asked Questions

What documents should I request in eDiscovery?
Request all electronically stored information (ESI) including emails, documents, databases, social media, text messages, and any digital communications relevant to your case. Focus on the time period and subject matter at issue.
When should I serve eDiscovery requests?
Serve eDiscovery requests during the discovery phase after initial pleadings are filed. Follow your jurisdiction's rules of civil procedure and any court-ordered discovery schedule.
How specific should my document requests be?
Be specific enough to identify relevant documents but broad enough to capture all potentially relevant evidence. Include specific date ranges, custodians, search terms, and document types.

Checklist

Electronic Communications

Request all email communications
Required

Include emails, email attachments, and email metadata from all relevant custodians

Request text messages and SMS
Required

Business and personal text messages related to the case

Request instant messaging records
Required

Slack, Teams, WhatsApp, and other messaging platform communications

Request social media content
Required

Posts, messages, and communications from LinkedIn, Facebook, Twitter, etc.

Request voicemail messages
Required

Business and personal voicemails related to the case

Business Records

Request business documents and records
Required

Contracts, agreements, invoices, receipts, and business correspondence

Request financial documents
Required

Bank statements, credit card records, financial reports, and accounting records

Request employee and HR records
Required

Personnel files, performance reviews, disciplinary records, and employment contracts

Request meeting minutes and notes
Required

Board meetings, staff meetings, and any meeting documentation

Request policy and procedure documents
Required

Company policies, procedures, handbooks, and guidelines

Request corporate formation documents
Required

Articles of incorporation, bylaws, shareholder agreements, and board resolutions

Legal Documents

Request all contracts and agreements
Required

Written contracts, oral agreements, amendments, and related correspondence

Request legal correspondence
Required

Letters, memos, and communications with attorneys, clients, and third parties

Request legal filings and pleadings
Required

Court filings, legal documents, and related materials

Request insurance policies and claims
Required

Insurance policies, claims files, and related documentation

Multimedia Evidence

Request photographs and video recordings
Required

Digital photos, videos, surveillance footage, and multimedia content

Request audio recordings
Required

Phone calls, meetings, interviews, and other audio content

Request presentations and slides
Required

PowerPoint presentations, slide decks, and presentation materials

Data Systems

Request database records and exports
Required

Customer databases, transaction records, and system data exports

Request spreadsheets and data files
Required

Excel files, CSV files, and other structured data

Request calendar and scheduling records
Required

Electronic calendars, appointment books, and scheduling records

Request contact lists and directories
Required

Contact databases, address books, and contact information

Request backup and archive files
Required

System backups, archived data, and historical records

Digital Storage

Request cloud storage content
Required

Google Drive, Dropbox, OneDrive, and other cloud storage files

Request local computer files
Required

Desktop, documents, downloads, and local file storage

Request mobile device data
Required

Smartphone and tablet data, apps, and device content

Request external storage devices
Required

USB drives, external hard drives, and removable media

Online Presence

Request website and online content
Required

Website content, blog posts, and online publications

Request online account information
Required

Social media accounts, online services, and digital accounts

Technical Information

Request document metadata
Required

File creation dates, modification dates, author information, and technical details

Request system and access logs
Required

Computer logs, access records, and system activity logs

Request network and internet records
Required

Internet browsing history, network activity, and online activity records

External Communications

Request third-party communications
Required

Communications with vendors, customers, partners, and other third parties

Expert Materials

Request expert reports and opinions
Required

Expert witness reports, evaluations, and professional opinions

Investigation

Request investigation materials
Required

Internal investigation reports, findings, and related materials

Compliance

Request compliance and audit records
Required

Compliance reports, audit findings, and regulatory documentation

Training

Request training and educational materials
Required

Training manuals, educational content, and learning materials

Marketing

Request marketing and promotional materials
Required

Marketing campaigns, advertisements, and promotional content