This template is a litigation hold notice that may be distributed to a client's employees and staff. It assumes that no lawsuit has been filed but that the client may reasonably anticipate litigation. This template includes practical guidance and drafting notes. Once a party reasonably anticipates litigation, it must suspend its routine document retention and destruction policies and put in place a litigation hold to ensure preservation of relevant documents. See Wagstaffe Prac. Guide: Fed. Civ. Proc. Before Trial ยง 33-IV[C][1]; Silvestri v. GMC, 271 F.3d 583, 591 (4th Cir. 2001); see also Zubulake v. UBS Warburg LLC, 220 F.R.D. 212, 218 (S.D.N.Y. 2003). This litigation hold notice or memorandum notifies a client's relevant employees of their duty to preserve and ensures the client meets its legal responsibilities. The duty to preserve evidence is not limited to paper documents or to the company's own computer systems and central server. Rather, this duty applies to all documents ...