Consider in Zubulake v. UBS Warburg, a case focused on the duties of in-house and outside counsel related to litigation holds and document retention policies. Although UBS Warburg claimed to have issued and reissued litigation holds, the court concluded that “a party cannot reasonably be trusted to receive a litigation hold instruction once and to fully comply with it without the active supervision of counsel.” The court suggested instructions for in-house and outside counsel to follow as a [...]