- IT people will generally not use the proper tools to preserve
- IT people will generally not appreciate the legal importance of preserving all data attributes. [Case study: Lotus Notes administrator copies and pastes e-mails from custodian's folders into a "litigation" folder.]
- IT people will generally not document what they are doing. How will you know what they captured and what they didn’t? [Case study: IT group sends us 300 tapes. Lawyers want to know whether all of John Smith's e-mail and documents are on those tapes. Do we know?]
I am all in favour of self-help and sensible practicable solutions to e-discovery problems. But let’s do it right, folks.