"It is not sufficient to notify all employees of a litigation hold and expect that the party will then retain and produce all relevant information. Counsel must take affirmative steps to monitor compliance so that all sources of discoverable information are identified and searched."
- Judge Scheindlin
"While a litigant is under no duty to keep or retain every document in its possession ... it is under a duty to preserve what it knows, or reasonably should know, is relevant in the action."
- Judge Scheindlin
"This is not to say that counsel will necessarily succeed in locating all such sources, or that the later discovery of new sources is evidence of a lack of effort."
- Judge Scheindlin
"[If it is not feasible to speak with every key player] counsel must be more creative. It may be possible to run a system-wide keyword search; counsel could then preserve a copy of each 'hit'."
- Judge Scheindlin
"-prosecutors should determine whether the corporation's employees are adequately informed about the compliance program and are convinced of the corporation's commitment to it. -[this] may result in a decision to charge only the corporation's employees and agents."
- Judge Scheindlin