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Guide 5: Identifying the Right Custodians in Electronic Disclosure

How to choose the people and repositories whose data gets collected, and defend those choices. Covers custodians and non-custodial sources, shared mailboxes, department a l repositories, service accounts and former employees, with a structured approach to custodian interviews so key material does not surface late.

35 pages · 38 min read

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Guide 5. Identifying the Right Custodians in Electronic Disclosure

Custodians and non-custodial sources; shared mailboxes, department a l repositories, service accounts, former employees and organisational data - how to choose the people whose documents get collected, defend the choices, and interview them so nothing surfaces late.

12 From register to DRD: drafting Section 2 custodian answers

13 Worked example 1: Aldgate's register - from 30 names to 9 custodians

14 Worked example 2: the hot custodian - Marsh from both sides of the litigation

15 Worked example 3: the sources with no owner - contracts@ and the GmbH

31 How a specialist laboratory can assist

Custodian interview: Part A role and events, Part B systems and habits, Part C personal-channel exposure, Part D preservation and conduct.

Cite as: Joseph Naghdi, Guide 5: Identifying the Right Custodians in Electronic Disclosure, Computer Forensics Lab, https://e-discovery.uk/library/identifying-the-right-custodians-in-electronic-disclosure/pdf.

Instruct the practice

Bring us in early. Defensibility is built, not retrofitted.

Whether you are responding to a regulator, preparing for disclosure, or scoping an internal investigation, start the chain of custody with a short, confidential conversation.

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