Nolene asks:
"Do the courts actually care how the records are stored as long as theycan be produced when requested and any destruction can be proved to bedone on a regular basis according to your retention schedule and ishalted if any litigation is pending? What does it matter to them if twodepartments share a box?"
 
The answer here is maybe. When we produce records as requested through Subpoena, we always keep a log of what physical materials came from who & where - boxes in storage, office, workroom, etc. Sometimes we'll need to describe a room or a storage area. Often we'll need to provide a procedure or a practice (or a retention schedule). This is generally what a paralegal handles, but sometimes I will do it. Depends on the matter and who I'm working with (outside or inside counsel) and the sensitivity of the issue. We're a small team so we all pitch in. 
 
We may need to furnish an outline of how we back up our systems, archive our email, and/or handle our e-docs. Have to be ready no matter what.
 
During the meet and confer, you'll have to review all your places of storage and practices. I've only had to do this for computer systems though...so far.
 
Rock on!
SharonSharon Burnett Seattle Washington USA "If it ain't broke, take it apart and see why. If it is broke, take it apartand see why."
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