Over the years we have been exposed to thousands of companies’ approaches to litigation holds and I’m often surprised by the wide variance in the approaches. One thing for certain is that the sensitivity and awareness to the need and legal requirement for litigation holds surrounding Electronically Stored Information is well entrenched with most organizations’ legal counsel. It has taken a while, but since the 2006 amendments to the Federal Rules of Civil Procedure organizations, large and small, are getting it. Is it all of them? Clearly not; but hey, baby steps, right? As an entity that lives and breathes ESI day-in and day-out, we sometimes lose sight of the fact that organizations that aren’t exposed to it all of the time have some differing opinions and points of view than perhaps what the industry views as best practices. One area where this holds true is the comprehensiveness of the hold. Too often stakeholders want to take the path of least resistance and end up woefully short of their duties. Not as often, but enough to make it an issue, we find organizations that go way overboard on their preservation duties. Clearly, there has to be a middle-ground, no? Read on as I explore the facets of a Defensible Preservation Plan.