Questionário de custodiante para e-discovery com Claude

---
name: ediscovery-custodian-questionnaire
description: Generate a structured custodian interview questionnaire from a legal-hold scope document. Given the hold's matter type, key issues, and custodian role, the skill outputs a draft questionnaire — with organized sections for data locations, communication channels, device inventory, and role-specific follow-up questions — that the legal-ops manager reviews before sending to the custodian. Use during the early data-collection phase of litigation, regulatory investigation, or internal inquiry.
---

# E-discovery custodian questionnaire

## When to invoke

Invoke this skill once per custodian, after the legal-hold scope has been documented and before custodian interviews begin.

Typical callers:

- Legal-ops managers running the custodian identification and data-collection phase of a litigation hold
- Inside counsel coordinating preservation obligations with IT for a regulatory inquiry
- Outside counsel directing in-house staff through the initial scoping interviews for a government investigation

Do NOT invoke this skill for:

- **Legal interpretation of hold obligations.** Whether a particular custodian is legally required to preserve data is a judgment call for counsel. This skill drafts the questionnaire; counsel decides who is a custodian and what the hold covers. Consult counsel before finalizing scope.
- **Attorney-client privileged custodian strategy.** Notes or strategy documents describing which custodians are most significant to the defense theory are work product. This skill generates a data-collection questionnaire, not a privileged strategy memo.
- **Auto-sending questionnaires.** The legal-ops manager reviews and edits the draft before sending. The skill does not distribute.
- **Non-litigation HR investigations with separate privilege considerations.** Dual-purpose investigations (employment matters that may become litigation) have distinct privilege rules; consult counsel before using this questionnaire template in those contexts.

## Inputs

- Required: `hold_scope` — path to, or inline text of, the legal-hold scope document. Must include: matter name, matter type (e.g. `commercial_litigation | regulatory | internal_investigation`), key issues summary (1-5 sentences), relevant date range (start and optional end date), and the specific custodian's name and job title.
- Required: `custodian_role` — one of `executive | sales_ops | finance | engineering | legal | hr | it | other`. Drives the role-specific question modules.
- Optional: `data_sources_known` — array of data sources already identified in prior custodian interviews or the hold notice (e.g. `["Salesforce", "Gmail", "Slack", "local_laptop"]`). Pre-populates the data-location section.
- Optional: `matter_type_overrides` — additional question modules beyond the defaults for the `matter_type`. Examples: `antitrust_pricing`, `trade_secret`, `regulatory_subpoena`, `harassment`.
- Optional: `output_format` — `word_outline | numbered_list`. Default: `numbered_list`.

## Reference files

Read these from `references/` before generating. They are templates — replace the placeholder content with your firm's real hold language and question modules before running on production matters.

- `references/1-question-library.md` — organized library of interview questions by section (data locations, communications, devices, role-specific modules) with the rationale for each question
- `references/2-hold-scope-template.md` — fillable template for the hold scope input. If the caller doesn't have a structured scope document, direct them to fill this template first.
- `references/3-custodian-interview-checklist.md` — the post-interview checklist the legal-ops manager completes after the custodian call, capturing gaps and follow-up items

## Method

Run these steps in order.

### 1. Parse hold scope and custodian context

Extract the following fields from `hold_scope`:

- `matter_name` — string
- `matter_type` — enum
- `key_issues` — string (preserve verbatim; these words drive section titles and question framing)
- `relevant_date_range_start` — ISO date
- `relevant_date_range_end` — ISO date or `ongoing`
- `custodian_name` — string
- `custodian_title` — string

If any required field is missing, emit a structured error before generating any questions:

```
error: "missing_required_fields"
missing: ["<field_name>", ...]
note: "Complete the hold scope document (references/2-hold-scope-template.md) before invoking the skill."
```

Do not generate a questionnaire against an incomplete scope. Incomplete scope produces questions that won't hold up under cross-examination or privilege challenges.

### 2. Select question modules

Map `matter_type` and `custodian_role` to the question modules to include. The base modules run on every questionnaire; role modules and matter-type modules stack on top.

**Base modules (always included):**
- Data locations (where does the custodian store work-related data — email, shared drives, local devices, personal accounts, third-party services)
- Communication channels (platforms used for work-related communications, including informal channels: SMS, WhatsApp, personal email)
- Device inventory (company-issued and personal devices used for work in the relevant period)
- Data retention practices (does the custodian delete email, clear instant messaging, use auto-delete settings)
- Relevant date range check (did the custodian's role change during the relevant period; was the custodian on leave)

**Role modules (add based on `custodian_role`):**
- `executive`: board communications, document-management platforms, assistant-maintained files, off-channel communications (Signal, encrypted apps)
- `sales_ops`: CRM data, deal documents, pricing approval trails, counterparty communications
- `finance`: ERP exports, expense platforms, wire-approval workflows, financial model files
- `engineering`: version-control repositories, CI/CD logs, issue trackers, internal wikis
- `hr`: HR platform records, performance documentation, separation agreements, confidential complaint files
- `it`: backup schedules, endpoint MDM logs, email archive configuration, litigation-hold system accounts

**Matter-type modules (add based on `matter_type`):**
- `commercial_litigation`: contract documents, communications with named counterparty, approval chains for disputed transactions
- `regulatory`: regulator correspondence, internal compliance reviews, any prior government requests
- `internal_investigation`: subject-related HR records (if permitted by counsel), escalation logs, any prior complaints

### 3. Generate draft questionnaire

Format the questionnaire as numbered sections. Within each section, list questions individually with a blank follow-up line beneath each question labeled "Response:" so the interviewer can fill it in.

Include at the top:
- Matter name and matter number (if provided)
- Custodian name and title
- Interviewer name (blank for interviewer to fill)
- Interview date (blank)
- Confidentiality notice: "This interview is conducted for purposes of legal hold. Responses may be protected by attorney-client privilege and/or work-product doctrine. Do not share the contents of this questionnaire outside the legal team without authorization from counsel."

Why numbered sections rather than a flat list: numbered references survive editing across multiple review rounds and are citation-friendly if the questionnaire is produced in litigation or referenced in a hold-certification record.

Why the confidentiality header is generated by the skill: legal-ops managers sometimes omit it when drafting ad hoc. The skill includes it by default; counsel can delete if the specific matter doesn't warrant it. Consult counsel on privilege framing for each matter.

### 4. Flag high-risk items

After the questionnaire, emit a `## Legal-ops notes` section (not part of the custodian-facing document) flagging:

- Any questions that touch potentially privileged materials (label: `[privilege-flag]`)
- Any questions that reference specific named individuals other than the custodian (label: `[third-party-flag]`)
- Any data-retention answers that may indicate potential spoliation risk (label: `[spoliation-watch]`)

These flags are for the legal-ops manager and counsel only. The custodian does not see this section.

## Output format

Always emit two sections separated by a horizontal rule: the custodian-facing questionnaire and the legal-ops notes section.

**Literal example:**

```
# Custodian Interview Questionnaire
Matter: Acme Corp v. Beta LLC — Case No. 2026-CV-0044
Custodian: Jordan Smith, VP Sales Operations
Interviewer: ________________
Date: ________________

CONFIDENTIALITY NOTICE: This interview is conducted for purposes of legal hold
in the matter referenced above. Responses may be protected by attorney-client
privilege and/or work-product doctrine. Do not share the contents of this
questionnaire outside the legal team without authorization from counsel.

---

## Section 1 — Data Locations

1. Please list all locations where you store work-related documents and files,
   including email accounts, shared drives, local folders, and any personal
   accounts you use for work purposes.
   Response:

2. Do you use any file-sync services (Dropbox, Google Drive personal, iCloud)
   to store work-related files?
   Response:

3. Do you have access to shared network drives or departmental SharePoint sites?
   If yes, please list them.
   Response:

## Section 2 — Communication Channels

4. What platforms do you use for work-related communications? Please include
   all platforms, even ones used informally (Slack, Teams, WhatsApp, personal
   email, SMS).
   Response:

5. Have you communicated with [Counterparty Name] or any Beta LLC employees
   using personal email or messaging apps during the period January 1, 2023
   through June 30, 2025?
   Response:

## Section 3 — Device Inventory

6. List all devices — company-issued and personal — that you used for
   work-related activities during the relevant period.
   Response:

7. Have any devices been replaced, repaired, wiped, or disposed of since
   January 2023?
   Response:

## Section 4 — Sales Operations (Role-Specific)

8. Which CRM do you use to manage deal records and customer communications?
   Do you retain local copies of CRM exports or reports?
   Response:

9. Were you involved in pricing approvals or contract modifications with
   Beta LLC? If yes, where are those approval records stored?
   Response:

---

## Legal-ops notes (not for custodian)

- Q5: References communications with named counterparty. [third-party-flag]
  Confirm with counsel which Beta LLC individuals are covered by the hold.
- Q9: Pricing approval chain may touch financial records separately held
  by finance. Confirm finance custodians are also interviewed. [privilege-flag
  if approvals involved in-house counsel]
```

## Watch-outs

- **Scope creep into legal advice.** The questionnaire asks where data lives; it does not ask whether the custodian believes they had an obligation to preserve it. Guard: the skill never generates questions that ask the custodian to characterize their own legal duties. Questions of the form "Did you know you were required to preserve X?" are legally loaded and are excluded from the question library.
- **Omission of informal channels.** Custodians routinely underreport personal email, SMS, and messaging apps unless explicitly asked. Guard: the base communication-channels module always asks about personal accounts, informal messaging, and encrypted apps — by name, not generically. If `data_sources_known` includes no informal channels, the skill adds a `[completeness-flag]` note in the legal-ops section.
- **Privilege header omission.** Ad hoc custodian questionnaires often lack a privilege/confidentiality header, which can complicate work-product assertions later. Guard: the skill includes the header on every output. Counsel removes it only with intentional deletion, not by accident.
- **Spoliation risk not surfaced.** A custodian who reveals they use 30-day auto-delete in their email client is a spoliation risk if the hold predates notice. Guard: data-retention questions are in the base module on every questionnaire; the legal-ops notes section flags any retention answer that mentions deletion or auto-expiry during the relevant period with a `[spoliation-watch]` label.
- **Matter-type mismatch.** Using the commercial-litigation module for a government regulatory inquiry may omit questions about prior government contact that are standard in regulatory custodian interviews. Guard: the skill selects matter-type modules from the explicit mapping in step 2 and emits a warning if `matter_type` is ambiguous or not in the enum: "Matter type not recognized — defaulting to commercial_litigation. Confirm with counsel before proceeding."
- **Stale question library.** The question library in `references/1-question-library.md` is a template. Legal-ops teams that don't update it for their firm's specific platforms (their actual CRM, their actual archive solution) will generate questions asking about platforms the firm doesn't use. Guard: the question library includes a `last_updated` field and the skill emits a warning when it is more than 12 months old: "Question library has not been updated in over 12 months. Review references/1-question-library.md for platform accuracy."

# Custodian Interview Question Library — TEMPLATE

> Replace this template's contents with questions calibrated to your firm's actual platforms, matter types, and typical custodian roles. The ediscovery-custodian-questionnaire skill reads this file on every invocation. Questions that reference tools your organization doesn't use will confuse custodians and reduce the quality of responses.
>
> This library is a starting point — not a complete set for any specific matter. Consult counsel before finalizing questions for any specific hold.

**last_updated:** {YYYY-MM-DD} — bump on every update. The skill warns when this date is more than 12 months old.

---

## Base module — Data locations

> Used on every questionnaire regardless of role or matter type.

### Q-DL-01
Please list all locations where you store work-related documents and files. Include: email accounts (company and personal), shared drives (SharePoint, Google Drive, Box, Dropbox), local folders on your computer, USB drives, and any external hard drives.

**Rationale:** Open-ended first question to inventory all obvious sources before probing specific platforms. Intentionally broad.

### Q-DL-02
Do you use any personal cloud storage (Dropbox personal, Google Drive personal, iCloud Drive, OneDrive personal) to store work-related files or email attachments?

**Rationale:** Custodians often move files to personal cloud for convenience; this is a common gap in corporate holds.

### Q-DL-03
Do you have access to shared network drives or departmental SharePoint/Teams sites? If yes, please list the drive paths or site names.

**Rationale:** Shared drives hold the custodian's contributions to collaborative work and may hold documents relevant to the matter that are not in their personal email.

### Q-DL-04
Have you ever stored work-related files on a device that is no longer in your possession (e.g. a prior company laptop, a device you returned to IT, a personally-owned device you no longer use)?

**Rationale:** Captures devices that may have been wiped or disposed of and is an early spoliation-risk indicator.

---

## Base module — Communication channels

> Used on every questionnaire.

### Q-CC-01
What platforms do you use for work-related communications? Please list every platform, including those used informally: Slack, Microsoft Teams, Zoom chat, Google Chat, WhatsApp, iMessage, SMS, personal email, LinkedIn messages, and any others.

**Rationale:** Informal channels are routinely underreported. Asking by name significantly improves completeness.

### Q-CC-02
Do you use any encrypted or ephemeral messaging apps for work-related communications? Examples include Signal, Telegram, Wickr, Confide, or Snapchat.

**Rationale:** Off-channel apps are a significant e-discovery gap and may be subject to preservation obligations. Consult counsel if custodian confirms use.

### Q-CC-03
Have you ever used a personal email account (not your company-issued address) to send, receive, or forward work-related communications? If yes, which account(s)?

**Rationale:** Personal email use for work is common; these accounts are outside corporate archive and require separate preservation steps. Consult counsel on collection approach.

### Q-CC-04
Are you aware of any communications on any platform that you believe may be relevant to the matter described in your legal-hold notice?

**Rationale:** Open-ended cue that encourages the custodian to surface items they believe are relevant, which may include platforms or topics not covered by earlier questions.

---

## Base module — Device inventory

> Used on every questionnaire.

### Q-DV-01
List all devices — company-issued and personal — that you used for work-related activities during the relevant period: laptops, desktop computers, tablets, smartphones, and any other devices.

**Rationale:** Complete device inventory is required before IT can issue appropriate preservation instructions.

### Q-DV-02
Have any of the devices listed above been replaced, repaired, wiped, or disposed of since [HOLD_DATE_START]? If yes, what happened to the data on that device?

**Rationale:** Key spoliation-risk indicator. [HOLD_DATE_START] is automatically populated from the hold scope.

### Q-DV-03
Do you use a mobile device management (MDM) profile on your personal phone for company email or apps? Do you know whether your company email is backed up by the company system on your personal device?

**Rationale:** MDM enrollment means IT may already have visibility into the device; the answer determines whether separate custodian action is needed.

---

## Base module — Data retention practices

> Used on every questionnaire.

### Q-RT-01
Do you have any auto-delete or auto-archive settings configured on any of your email accounts? If yes, after how many days are messages deleted?

**Rationale:** Auto-delete settings during the relevant period are a primary spoliation flag.

### Q-RT-02
Do you regularly clear your instant-messaging history on any platform (Slack, Teams, etc.)? If yes, which platforms and how often?

**Rationale:** Manual deletion during the hold period may be spoliation depending on notice date; captures the custodian's retention habits.

### Q-RT-03
Did you receive a legal-hold notice for this matter? When did you receive it? Did you take any steps in response to the notice?

**Rationale:** Confirms actual receipt of the hold and the custodian's response — both are important for the hold-compliance record and for identifying any deletions that postdate notice.

---

## Role module — Executive

> Add to questionnaire when `custodian_role` = `executive`.

### Q-EXEC-01
Do you use any board-communication platforms (Diligent, Boardvantage, OnBoard) or board-meeting-minutes systems? If yes, do you retain copies of board materials on your devices?

### Q-EXEC-02
Does an executive assistant or administrative support staff manage your calendar, email, or documents? If yes, what platforms does your assistant use on your behalf?

### Q-EXEC-03
Do you use any apps configured specifically to avoid corporate archiving — for example, apps with automatic message deletion or end-to-end encryption not covered by the corporate archive?

---

## Role module — Sales operations

> Add to questionnaire when `custodian_role` = `sales_ops`.

### Q-SALES-01
Which CRM system(s) do you use to manage customer records, deal pipelines, and communications? (e.g. Salesforce, HubSpot, Dynamics)

### Q-SALES-02
Do you export CRM data to local spreadsheets, Google Sheets, or Excel files? If yes, where are those files stored?

### Q-SALES-03
Are you involved in pricing approvals, contract modifications, or discount authorizations? If yes, where are those approval records maintained?

### Q-SALES-04
Do you maintain contact with customers or prospects outside the CRM using personal email or messaging apps?

---

## Role module — Finance

> Add to questionnaire when `custodian_role` = `finance`.

### Q-FIN-01
Which financial systems do you use for transaction processing, reporting, or approvals? (e.g. NetSuite, SAP, QuickBooks, Coupa)

### Q-FIN-02
Do you retain local copies of financial reports, budget models, or reconciliation files on your device or personal cloud storage?

### Q-FIN-03
Are you involved in wire approvals, vendor payment authorizations, or intercompany transfers? Where are those approval records maintained?

---

## Role module — Engineering

> Add to questionnaire when `custodian_role` = `engineering`.

### Q-ENG-01
Which version-control repositories do you have access to (GitHub, GitLab, Bitbucket, Azure DevOps)? Are any repositories hosted outside the company organization?

### Q-ENG-02
Do you use project or issue-tracking tools (Jira, Linear, Asana, GitHub Issues)? Are your comments, assignments, and history in those tools?

### Q-ENG-03
Do you have copies of source code, technical designs, or API specifications on personal devices or personal cloud storage?

---

## Role module — IT

> Add to questionnaire when `custodian_role` = `it`.

### Q-IT-01
What email archiving and e-discovery platforms does the company use? Are you the administrator?

### Q-IT-02
What is the company's current email retention policy? Have there been any changes to the retention policy in the past 24 months?

### Q-IT-03
Has the company's email archive configuration or backup schedule changed since [HOLD_DATE_START]?

### Q-IT-04
Are any IT systems scheduled for decommission, migration, or replacement in the next 90 days?

---

## Matter-type module — Commercial litigation

> Add to questionnaire when `matter_type` = `commercial_litigation`.

### Q-LIT-01
Are you aware of any communications with [COUNTERPARTY_NAME] or its employees during the relevant period? On which platforms?

### Q-LIT-02
Do you have any documents related to [KEY_ISSUES_SUMMARY]? Where are those documents located?

### Q-LIT-03
Were you involved in the negotiation, approval, or performance of the contract or transaction at issue? If yes, describe your role.

---

## Matter-type module — Regulatory

> Add to questionnaire when `matter_type` = `regulatory`.

### Q-REG-01
Have you ever received a request for documents or information from any government agency, regulator, or law enforcement related to the subject matter of this hold?

### Q-REG-02
Are you aware of any prior compliance reviews, internal audits, or investigations related to the subject matter?

### Q-REG-03
Have you communicated with external legal counsel specifically about regulatory compliance in the relevant area? On which platforms?

---

## Matter-type module — Internal investigation

> Add to questionnaire when `matter_type` = `internal_investigation`. Consult counsel before using — internal investigations may have distinct privilege and employment-law considerations that affect which questions are appropriate.

### Q-INV-01
Are you aware of any complaints, concerns, or incidents related to the subject matter of this investigation that were reported to HR, legal, or management?

### Q-INV-02
Have you communicated with any individual about the subject matter of this investigation outside of normal business channels?

### Q-INV-03
Are there any documents, communications, or records related to the subject matter that you believe the investigating team should be aware of?

# Legal Hold Scope — Input Template

> Fill this template before invoking the ediscovery-custodian-questionnaire skill. The skill requires a structured scope document; incomplete scope produces questions that may not hold up under cross-examination or privilege challenges. Consult counsel before finalizing hold scope.

---

## Matter identification

**Matter name:** {e.g. Acme Corp v. Beta LLC}

**Matter number / case number:** {internal matter ID or court case number, if assigned}

**Matter type:** {select one: commercial_litigation | regulatory | internal_investigation}

**Matter-type overrides (optional):** {list any additional question modules needed, e.g. antitrust_pricing, trade_secret, regulatory_subpoena, harassment}

---

## Scope

**Key issues summary:** {1-5 sentences describing the core legal issues driving the hold — these words will appear in question framing, so be specific. Example: "Disputed pricing terms under a software license agreement; alleged breach of most-favored-customer clause; counterparty claims vendor secretly provided lower pricing to competitors during the contract term."}

**Relevant date range — start:** {YYYY-MM-DD}

**Relevant date range — end:** {YYYY-MM-DD, or "ongoing"}

**Named counterparties / subjects:** {list organizations and individuals relevant to the hold; these will appear in communication-channel questions}

---

## Custodian

**Custodian name:** {First Last}

**Custodian title:** {e.g. VP Sales Operations}

**Custodian role category:** {select one: executive | sales_ops | finance | engineering | legal | hr | it | other}

**Custodian department / business unit:** {optional — used to tune shared-drive and team-communication questions}

---

## Known data sources (optional — populate from prior interviews or IT)

> List any platforms or data sources already confirmed in prior custodian interviews or the IT data-map. Pre-populates the data-location section and avoids redundant questions for well-documented custodians.

- {e.g. Salesforce — CRM, deal records}
- {e.g. Gmail corporate — primary email}
- {e.g. Slack — team communications}
- {e.g. MacBook Pro (company-issued, serial XXXX) — local files}

---

## Hold status

**Hold notice issued date:** {YYYY-MM-DD}

**Custodian notified:** {yes | no | pending}

**Prior holds on this custodian:** {yes | no — if yes, list matter name(s)}

---

## Interviewer

**Interviewer name:** {First Last}

**Interviewer role:** {legal-ops manager | inside counsel | outside counsel}

**Planned interview date:** {YYYY-MM-DD}

---

## Notes for counsel

> Use this section to flag any concerns or instructions before the questionnaire is generated. Examples: which questions should be omitted for privilege reasons; whether the investigation is dual-purpose (employment + litigation); any custodian-specific context the interviewer should know before the call.

{Free text — for legal team use only. Does not appear in custodian-facing questionnaire.}

# Post-Interview Custodian Checklist — TEMPLATE

> Complete this checklist within 24 hours of each custodian interview. The legal-ops manager submits the completed checklist to inside counsel. Do not store this checklist alongside the custodian-facing questionnaire — this is a work-product document. Consult counsel on appropriate storage and handling.

---

## Interview record

**Matter:** {matter name and number}

**Custodian:** {name and title}

**Interviewer:** {name}

**Interview date:** {YYYY-MM-DD}

**Interview format:** {in-person | video call | phone}

**Duration:** {HH:MM}

---

## Hold confirmation

- [ ] Custodian confirmed receipt of hold notice
- [ ] Custodian understood the relevant date range
- [ ] Custodian confirmed they have NOT deleted relevant materials since receiving the hold notice
- [ ] Custodian confirmed they will NOT delete relevant materials going forward
- [ ] If no hold notice received yet: Oral hold instruction given; written follow-up required within 24 hours

**Notes:**

---

## Data sources confirmed

> List every platform, account, and device the custodian confirmed as holding potentially relevant materials. This list becomes the collection scope for IT.

| Source | Platform/Tool | Account/Path | Status |
|---|---|---|---|
| Email | {e.g. Gmail corporate} | {email@company.com} | {to collect / already preserved / no relevant data} |
| Shared drive | {e.g. SharePoint Sales} | {URL or path} | {to collect / already preserved / no relevant data} |
| CRM | {e.g. Salesforce} | {custodian login} | {to collect — IT action required} |
| Messaging | {e.g. Slack} | {workspace + DMs} | {to collect} |
| Personal email | {e.g. Gmail personal} | {if disclosed} | {consent and collection method TBD with counsel} |
| Device | {MacBook serial XXXX} | {local files} | {IT forensic image requested} |

---

## Spoliation flags

> Record any answer that indicates data may have been deleted or is at risk of deletion. Escalate to counsel immediately.

- [ ] No spoliation flags identified
- [ ] Flag: {describe — e.g. "Custodian stated they cleared Slack DM history monthly; last clear was [DATE] — which postdates hold notice"}

**Escalation action:** {note any immediate steps taken}

---

## Informal channel flags

> Record any personal accounts or informal messaging apps the custodian disclosed. Each requires counsel's direction on collection approach.

- [ ] No informal channels disclosed
- [ ] Personal email: {account(s)}
- [ ] Personal messaging: {platform(s)}
- [ ] Encrypted/ephemeral apps: {platform(s)}

**Counsel notified:** {yes / no / pending}

---

## Follow-up items

> List any questions that were unanswered, topics that need clarification, or additional custodians identified during the interview.

| Item | Owner | Due date |
|---|---|---|
| {e.g. Confirm pricing approval records location with IT} | {legal-ops} | {date} |
| {e.g. Custodian to provide serial numbers for personal devices} | {custodian} | {date} |
| {e.g. Additional custodian identified: [Name, Title] — add to hold list} | {inside counsel} | {date} |

---

## Collection scope summary

> Summarize the collection instructions for IT based on this interview. This section is the IT hand-off.

**IT action items:**

1. {e.g. Preserve email archive for custodian@company.com — full account — relevant period: Jan 1, 2023 – June 30, 2025}
2. {e.g. Collect Salesforce records associated with custodian login — export deal history and communications for named counterparty}
3. {e.g. Image MacBook Pro serial XXXX before custodian hardware refresh scheduled for [DATE]}

**Collection deadline:** {YYYY-MM-DD}

---

## Sign-off

**Checklist completed by:** ________________

**Date:** ________________

**Reviewed by counsel:** {yes / no / pending}