The assessment function requires that you consider all possible sources of ESI and then make informed judgments as to which possible sources require securing of their contents or extraction of a portion of their contents. Your goal is to reasonably reduce the number of potential sources of responsive ESI to a fraction of the total universe of sources under the custody and control of your client.
Demand digital-legal expertise
Locate and understand all electronic storage media
Determine reasonable and defensible approach for each subset of media
Make decisions in a timely manner, e-data is not self-preserving