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In our last article, we discussed the concept of “litigation readiness” and the benefits of implementing a records-management policy. When a company faces a lawsuit, it must navigate the universe of potentially relevant data. It must identify, preserve and collect relevant electronically stored information (ESI) on its computer system using forensically sound procedures capable of being validated, verified and repeated. The identification and preservation strategies discussed below are designed to protect companies from claims of spoliation and to enable the proper authentication of documents.