CONFIDENTIAL AND PRIVILEGED

insert date

insert addressees: insert addressees: senior managers/relevant employees and former employees/IT managers

insert case heading OR description of the case if pre-action

We OR the company may face a legal dispute concerning insert matter/transaction subject of dispute.

If the dispute is not resolved, it is likely that we will be obliged to disclose relevant documents, including electronic records, that are or have been in our OR the company's control, whether they are helpful to our case or not.

However, certain relevant documents are protected from being inspected (that is to say, actually seen) by our opponent OR name of opponent. These include documents that are ‘privileged', such as certain confidential communications between us OR the company and our lawyers. Please see the ‘Definitions' section below for more information about the meaning of ‘documents', ‘control' and ‘privilege'.

Accordingly, it is important that we take appropriate steps to identify and preserve all documents that may be relevant to the dispute. However, it is also important to ensure that we: