I consider preservation letters a gift because it gives me insight into the other side’s real intention. If it says “save all the metadata,” then I know they are an ignoramous. But if they are specific in their request, then I know that I have to have my ducks in a row because they know exactly what they’re doing.
Craig makes a great point, if you simply say “all metadata”, you’re asking for a bunch of back and forth between the parties, and requests of the court before you finally get to an acceptable definition of what you’re actually looking for, as opposed to simply knowing what you’re looking for and asking for it. As usual, Craig nails it!
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