>>In Zubulake V, Judge Schiendlin clearly makes it COUNSEL'S
responsibility to 1) identify, 2) communicate, 3) interview, and 4)
monitor the hold.<<

I understand your statement that it is counsel's responsibility to do
these things.  Do you really believe that counsel can possibly do it
without assistance of others?  It has been my experience over the years,
that counsel, especially external counsel, cannot do these things
without assistance.  

Are they responsible, absolutely.  They are the ones who will have to
respond to the court.  Can they do it by themselves, absolutely not.
And they are not necessarily the one who will be the one who is asked
the questions.  

Bill R

Bill Roach, CRM
Enterprise EDMS Coordinator
State of North Dakota
ITD/Records Management
701-328-3589
 

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