Extract to table

All routine, scheduled, or policy-based destruction of documents and ESI must cease immediately for the categories of materials and the custodians identified herein

Because this litigation hold is being issued on the date the Complaint was filed, certain of the reports described below may be anticipated but not yet published; to the extent any such report has already been published at the time this memorandum is received, all materials related thereto must be immediately preserved

Categories of Documents and ESI to Be Preserved The following categories describe the types of documents, ESI, and tangible materials that must be preserved under this litigation hold

Any document, ESI, or tangible item that is or may be relevant to the claims or defenses in this action—or that might reasonably lead to the discovery of relevant evidence—must be preserved, regardless of whether it falls neatly within one of the categories below

GPR Reports and Related Materials All documents and ESI relating to GPR's research reports targeting RGC must be preserved, including but not limited to: 1

Financial and Accounting Records All financial and accounting records relevant to the allegations contained in GPR's reports and to RGC's affirmative claims must be preserved, including but not limited to: 1