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Litigation Hold and Product History Chronology

A litigation hold built from the product's own records: agents find everyone who signed its history, catch departed mailboxes before they delete, and counsel signs the scope.

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Follow scope v2 from twelve custodians to forty-six ↓
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The problem

A hold scoped from the org chart while the mailboxes keep deleting

When a product claim arrives, the first hold usually goes to the people on today's org chart for that product line. The people who designed it, validated its process or signed its regulatory file a decade ago are often in other jobs, or gone.

A departed person's mailbox deletes on schedule unless someone stops it. When the other side asks for the product's whole history, the eDiscovery team finds out who was missed by reading signatures across design, plant, quality and filing systems, usually after some of that mail is already gone.

Built forLitigation counseleDiscovery managersParalegalsRecords managers

The Problem Today

Holds are scoped from an org chart, while the people who signed the product's history sit in eight systems and their mail deletes on schedule.

2 years
minimum kept for device quality records; mail has no floor published

Joined up by hand today

  • Org charts
  • Signatures
  • Retention
  • Timelines
  • Mail deleted on scheduleA departed person's mailbox goes unless someone stops it
  • History in eight systemsDesign, change, plant and filing records kept apart

The Solution

  1. Read the scopeCounsel's signed memo sets the product, the dates and the record types
  2. Find who signedAuthors, approvers and signers on the records, matched to the directory
  3. Catch the deletionsDeparted mailboxes compared with the retention schedule and the queue
  4. Counsel signsThe scope, the notices and the chronology export carry counsel's signature

Built-in controls

  • Records another unit holds are never opened
  • Counsel decides privilege; agents only flag
  • A hold release needs a second signature

What You Get

Counsel signs a hold that names everyone the records name, before any of their mail is lost.

150 h
of paralegal and counsel time returned per matter our estimate
  • A chronology with its recordsEach dated event quotes its record and signer
  • Holds checked in each systemVerified from the system's own hold report
  • Notices that name their recordsEach lists the person's own systems and records
One surgical table, one widened scope

Widening a litigation hold from an org chart to the product's records

A product claim about a powered surgical table was held a year ago with twelve custodians from an org chart. The other side now asks for the table's whole history, and counsel wants a second scope before the meet-and-confer.

demoThe matter, the table, the custodians and the item counts are sample data, and the plaintiff appears only as a masked ID.

  1. 01Morning

    Hold v1 covers two systems and 12 people from the org chart

    eDiscovery manager

    The hold map shows eight islands, one per system, with only email and the lifecycle system inside the first hold's dashed line. A ninth island sits behind a lock: records another unit holds, which this product never reads. Nothing about custodians or deletions shows until the agents have read the records.

  2. 02Morning

    46 custodians from signatures on the records, and 34 were never on hold

    eDiscovery manager

    He runs the agents. They read counsel's scope memo, map 4,201,000 items across eight systems, and read who authored, approved or signed each in-scope record. 46 people come back, 12 of them already on hold. 9 have left the company, and three of their mailboxes delete within days. Two names with weak evidence wait for a person.

  3. 03Morning

    Three departed mailboxes delete in 6, 7 and 8 days

    eDiscovery manager

    The departures list sorts the nine by deletion date under the schedule rule: mail deletes 24 months after a person leaves. A program lead, a regulatory affairs manager and a process validation engineer are next. Each row names the record that makes them a custodian. Two mailboxes were deleted years before the matter, with certificates on file.

  4. 04Morning

    Two possible custodians excluded, with the reason written down

    eDiscovery manager

    One possible was a guest named once in design review minutes; the other trained staff on a cable routing class. Neither signed a product record. He excludes both with that reason, which goes to counsel in his own words, and sends scope v2. The agents cannot widen or narrow the scope themselves.

  5. 0508:14

    Counsel opens the scope and the departures before she can sign

    Litigation counsel

    Scope v2 sits beside v1: the dates now run from the first design input, the records cover design, manufacturing, regulatory, labeling and correspondence, and eight systems replace two. A third party, the contract assembler that built the table for four years, gets a preservation letter drafted for counsel. Her sign button waits until she has opened the departures.

  6. 0608:16

    Signed: these custodians, systems and dates are preserved from now on

    Litigation counsel

    She signs with her own password, and the meaning prints beside the scope. Changing the possibles or the scope after this clears the signature. The notice drafter then writes one notice per active custodian from her approved template, each listing that person's own systems and records. The nine who left get no notice; their data is held in the systems.

  7. 0708:20

    Deletion suspended on three mailboxes before the queue reaches them

    eDiscovery manager

    Suspending a deletion only preserves, so it takes effect at once. He suspends all three, and the departures list turns them from days left to deletion suspended. The hold verifier confirms a minute later that the email archive removed them from its deletion queue. Mailboxes due next year move to hold requested.

  8. 0808:28

    The email archive's own report confirms 2,968,400 items held

    Records manager

    The records manager applies the hold in each system. The hold verifier reads that system's hold report and compares it with what was requested: 44 mailboxes, every custodian held. A system whose report cannot be read shows not verified, and the records manager confirms it by hand with a reason.

  9. 09Chronology

    Each event in the chronology opens the record it was built from

    Paralegal

    The product history runs in five lanes from design to correspondence, 46 events, each quoting its record. Opening the event for the unit counsel named shows its device history record: where it was assembled, its final test and who signed. Nothing in the chronology says why anything happened; that stays with counsel.

Three mailboxes that would have gone before the hold reached them

The departures the first hold missed, each with the record that makes the person a custodian.

Departed custodianRecord that names themMailbox deletes in
Program lead, surgical tables R&DDesign and development plan approved6 days
Regulatory affairs managerRegulatory assessment, 230 V configuration7 days
Process validation engineer, Plant 1Transfer process validation approved8 days

demoSample data, from the working solution. None was on the org chart the first hold used. All three were suspended before scope v2 went out to custodians.

Scope v2 adds 34 custodians and holds 44 mailboxes

How scope v2 adds up, as the custodian finder counted it.

On hold v1, from the org chart12
New, still at the company26
New, departed8
Custodians in scope v246
Mailboxes deleted before the mattercertificates on file2
Mailboxes to hold44

demoSample data, from the working solution.

Around the scope

Custodians, chronology and audit behind one legal hold

What counsel, the eDiscovery manager and the paralegal open after the scope is signed.

Chronology46 events in five lanes over the product's life, each with its record, signers and system. Two have a lawyer on the record and wait for counsel.
CustodiansAll 46 with role at the time, years, records signed, mailbox state and notice, each found from a signature, never from an org chart.
Outside the perimeterRecords another unit holds stay behind the fence. Counsel requests them from that unit; its signed confirmation is referenced and never opened here.
Audit trailEach signature, suspension, notice and verification with its reason, meaning and session, exportable with the hold log.

demoSample data, from the working solution.

Counsel signs the scope; nobody releases a hold alone

Each person acts in their own session, with their own password.

eDiscovery manager
Sees
Custodians, departures and the possibles with their evidence
Signs
Decides possibles, suspends deletions, sends notices
Litigation counsel
Sees
The widened scope against the first and the departures
Signs
Signs the scope and the chronology export; rules on privilege
Records manager
Sees
Each system's hold request and its report
Signs
Applies holds and confirms by hand where a report cannot be read
Paralegal
Sees
The chronology events and their records
Signs
Accepts, edits or excludes events for counsel
Associate general counsel
Sees
A hold release and its overlap with other matters
Signs
Countersigns any release
Who reads the records

Eight agents read the product's records and none of them sends a notice

They read, map, match and draft. Counsel and the records team act.

Scope reader

Reads counsel's signed scope memo and lists items, dates and record types.

  • Never reads the court filing or complaint records
  • Never widens or narrows the scope
Records mapper

Finds which systems hold records for the product and counts them.

  • Never moves, copies or deletes a record
Custodian finder

Reads authors, approvers and signers on in-scope records and matches them to the directory.

  • Never adds a person from an org chart alone
Retention checker

Compares each mailbox and share with the retention schedule and the deletion queue.

  • Never suspends or permits a deletion itself
Notice drafter

Drafts each notice from counsel's template and tracks acknowledgments.

  • Never sends
  • Never changes counsel's wording
Chronology builder

Builds dated events from design, manufacturing, regulatory, labeling and correspondence records.

  • Never reads complaint, device report or field action records
  • Never says why something happened
Hold verifier

Reads each system's hold report and compares counts with the request.

  • Never applies or releases a hold
Release checker

Checks a release for overlap with other active matters.

  • Never releases anything

What litigation counsel ask about a litigation hold built from records

What is a litigation hold built from a product's records?

A litigation hold here starts from counsel's signed scope and the product's own records. Agents read who authored, approved and signed each record, match them to the directory, and flag anyone who has left and whose mail is due to delete.

Does it read the court filing or the allegation?

No. Counsel reads the filing. The agents work from counsel's signed scope memo, and the only claim-linked fact they hold is the unit counsel named.

What about complaint files and device reports?

They are held by the complaint handling unit. Counsel requests them from that unit, and its signed hold confirmation is referenced as one document. Nothing in it is opened, counted, dated or summarized here.

Who decides privilege on the chronology?

Counsel. Events with a lawyer on the record are flagged and stay in the chronology for the manufacturer's outside counsel; counsel rules on them before production.

Can a suspended deletion wait for the scope signature?

It does not have to. Suspending a deletion only preserves data, so the eDiscovery manager can do it at once, and counsel reads it in the scope.

How is a hold released?

Counsel requests the release with a reason, the release checker looks for overlap with other active matters, an associate general counsel countersigns after opening it, and the records manager applies it.

Commercial Compliance, Legal & Trade

Legal and corporate work beside the hold

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Bring the scope memo from one closed matter
and the custodian list it went out with.

We will read that product's records and show who signed its history but never got the notice.

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