I agree completely with Bil K's definition, but think he artfully boils it
down with his last paragraph:
At the end of the day, every one of my Requests for Production starts with
"Please produce any and all documents in your possession, custody or control
that refer or relate to..." The only documents an entity is reasonably
expected to keep in its possession, custody or control are its records...
If we could get our organizations and clients' organizations to understand
and adhere to that, well.... :)
Jesse Wilkins
CDIA+, EDP, LIT/ERM, ICP, ECMp, ERMs
IMERGE Consulting
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