Ad hoc, unsupervised Discovery efforts by management, IT departments and counsel could sink a case before it even gets started, a fact usually discovered much later, after expending significant time and money.

1. Become familiar with the organization's record retention and destruction policies.
2. Determine if policies were actively enforced and audited to ensure compliance
3. Communicate with IT personnel.
4. Gain a sound understanding of pertinent information systems.
5. Learn how information is created, maintained and destroyed
6. Identify and account for accessible and inaccessible electronically stored information
7. Confer with technicians to devise cost effective and valid methods of data collection.