Which of the following statements reflects the philosophy of your outside litigation counsel?

• Your company has a duty to preserve all information potentially relevant to pending or reasonably anticipated litigation
• The best offensive discovery strategy is to seek from your opponent everything potentially relevant
• In preparing responses to document request, their law firm templates are a fine starting point
• The best discovery outcomes are achieved through zealous advocacy
• Discovery delays usually benefit the party with the most to produce
• They must get the consent of opposing counsel or the court before using predictive coding
• The clawback provisions of the Federal Rules protect you from privilege waivers
• Producing parties must cover all of their own production cost