Secure some portion of that limited subset of data storage devices deemed to be potential sources of responsive ESI. These devices will be off-limits for perhaps years, so the fewer secured the better. Usually this means out-of-service computers and perhaps backup tapes that are pulled from rotation.
Demand digital-legal expertise
Secure potentially responsive data sources
Circulate litigation hold notice; include detailed instructions to key custodians to avoid spoliation
Assign custodian responsibility for dormant media
Establish chains of custody to assure authenticity and admissibility
Continually monitor, test, and document
Reduced volume of potentially responsive & other data stored in subset of client media: