I don't think Bill was suggesting that all ESI is a record, rather seeking
input on the approach of treating all ESI as a record for a short, specific
period. FOIA is generally very expansive compared to the more traditional
records series; and in the case of litigation, the records status of
something is irrelevant - it's whether it exists and is responsive that
determines its need for production. Consider that once a legal hold is
implemented, everything response may need to be  preserved for some period
of time, irrespective of its "recordness" or not, *and* may need to be
preserved for a much longer period than the retention period would warrant.
Or is that just an "ignorant approach" as well?
I don't know how I feel about the approach yet - gotta think about it some
more. But to call it "the same ignorant approach" really does a disservice
to the request and to the other organizations (including, apparently, the
GAO) who are considering that approach. I certainly don't believe it's an
"ignorant approach" at all.

-- 
Regards,

Jesse Wilkins
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blog: http://informata.blogspot.com
Twitter: http://www.twitter.com/jessewilkins

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