Ben,

I've not testified in court, but have submitted data for a number of
discovery requests and done a few depositions.

In each instance I needed to produce the retention schedule in effect
for the time period addressed by the discovery request.  If there were
changes made to the applicable schedules during that time, I was usually
asked to provide all versions for the timeframe.

Discovery requests usually asked for the entire retention schedule, at
first. But when I showed our counsel how voluminous this would be, they
usually negotiated a more narrow set of criteria so that I only had to
produce specific records series.

Pilar C. McAdam, CRM
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Los Angeles, CA

 
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