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American Bar Association

ABA Section of Litigation
Pretrial Practice & Discovery

E-Discovery and Sample Litigation Forms


The following sample documents are in PDF format, unless otherwise noted. (PDF)

“Zubulake” Letter

The letter advises clients of their obligation to preserve electronic data and contains recommended procedures for the use of e-mail.


Confidentiality and Joint Defense Agreement

This sample form can be used when your client’s and another lawyer’s client’s interest are aligned in litigation. Joint defense agreements can be important tools in preserving the attorney-client privilege and protecting communications between lawyers representing different parties that otherwise may not be privileged.


30(b)(6) Deposition Notice for Electronic Records Custodians

This notice will be especially helpful to practitioners who are still learning about the architecture of computer systems and how electronic data is stored.


Electronic Discovery Samples

Other Samples

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