Thinking Process:

1.  **Analyze the Request:**
    *   **Role:** Litigation Counsel to Trellick Automation.
    *   **Task:** Draft two documents in final form, ready to send.
        1.  Litigation Hold Notice (to custodians). Max 600 words.
        2.  Preservation Action Memo (to General Counsel). Max 400 words.
    *   **Governing Law:** Provided 5 points (Duty to preserve triggers, reasonable/proportional steps, no reliance on custodian self-selection, suspend auto-deletion, sanctions framework, hold notice requirements).
    *   **Facts:**
        *   Demand letter from Ridgeline Foods (defective proximity sensors, VX-9 model).
        *   Claim: $3.4M, two line-stoppage incidents in past 90 days.
        *   Relevant Period: Past 3 years (development of VX-9).
        *   Custodians/Sources at Risk:
            *   VP Eng Sara Okafor & team (6 engineers): Personal phone messaging app (auto-delete after 1 week).
            *   Contractors (Fenwick Embedded LLC): Email + messaging app.
            *   Company Slack: Deletes after 45 days.
            *   Jira & Git: Self-hosted.
            *   Test-bench telemetry: Overwrites on 21-day rolling basis.
            *   Marcus Bell (QA Lead, resigned): Laptop reimaging Friday, email deletion in 30 days.
            *   Shared Drive: "Spring cleanup" purges >24 months this weekend.
            *   CRM & Support Tickets (Vendor): Retains closed-ticket attachments for 12 months.
    *   **Constraints:**
        *   Hold Notice: <600 words, identify recipients, define subject matter/date, cover all at-risk sources (personal, contractors, auto-deletion), require acknowledgment, no merits/admissions.
        *   Action Memo: <400 words, list technical suspensions/collections/vendor actions outside the notice, assign ownership, set deadlines, order by urgency, identify single most time-critical action + why.

2.  **Drafting Document 1: Litigation Hold Notice**
    *   *Audience:* Identified custodians (Sara Okafor, Eng team, Contractors, IT/Admin for system preservation notice context). Actually, usually sent to employees/custodians directly. The prompt says "to be sent to identified custodians". I should address the relevant individuals/groups.
    *   *Content Requirements:*
        *   Identify Matter: Ridgeline Foods dispute (VX-9 sensors).
        *   Subject Matter/Date Range: VX-9 development (last 3 years), incidents (past 90 days).
        *   Sources: Email, Slack, Jira, Git, Personal Devices (messaging app), Test-bench telemetry, Shared Drive, Marcus Bell's data.
        *   Prohibitions: No deletion, no routine destruction, suspend auto-delete.
        *   Rule Compliance: Do not rely on self-selection (collective preservation needed for personal devices/apps). Acknowledge receipt. Point of contact.
        *   Tone: Formal, neutral (no liability admission).
    *   *Drafting Strategy:* Start with the notice header. State the obligation clearly. Define scope. List specific systems (including personal apps). Mention contractors. Require acknowledgment. Keep it tight to meet word count.

3.  **Drafting Document 2: Preservation Action Memo**
    *   *Audience:* General Counsel.
    *   *Content Requirements:*
        *   Technical suspensions/collections/vendor actions *outside* the hold notice (IT tasks, vendor contacts).
        *   Who owns each action (Dept/Role).
        *   Deadline for each.
        *   Ordered by urgency.
        *   Identify single most time-critical action + why.
    *   *Drafting Strategy:* Bullet points or table format for clarity. Prioritize based on the facts (Marcus Bell's laptop Friday, Shared Drive cleanup weekend, Messaging app auto-delete weekly, Slack 45 days).
    *   *Most Critical:* Marcus Bell's laptop reimaging is this Friday. If missed, data is lost immediately. Or the Shared Drive cleanup "this weekend". The prompt says "laptop scheduled... this Friday" and "cleanup... this weekend". Both are very urgent. However, personal device auto-delete (1 week) is also tight but Marcus Bell's specific departure process is a hard deadline for physical media. Let's evaluate:
        *   Marcus Laptop: Friday (2-3 days from "this morning").
        *   Shared Drive: Weekend (very soon).
        *   Personal App Auto-delete: Weekly rolling (constant risk, need to stop immediately).
        *   Most Time-Critical: Marcus Bell's laptop reimaging. Why? Because it is a specific, scheduled destruction event happening within 48 hours that cannot be undone once reissued.
    *   *Word Count:* Max 400 words.

4.  **Review and Refine:**
    *   *Check Word Counts:*
        *   Hold Notice: Must be <600.
        *   Memo: Must be <400.
    *   *Check Compliance:*
        *   Did I cover personal devices? Yes (Sara's app).
        *   Did I cover contractors? Yes (Fenwick).
        *   Did I cover auto-delete systems? Yes (Slack, App, Telemetry, Shared Drive).
        *   Did I avoid arguing merits? Yes.
        *   Did I require acknowledgment? Yes.
        *   Did I identify the most critical action in the memo? Yes.
    *   *Tone:* Professional legal counsel.

5.  **Drafting - Step-by-Step:**

    *   *Hold Notice:*
        *   Header: LITIGATION HOLD NOTICE.
        *   To: Engineering, QA, Sales/Support, IT Admins.
        *   Matter: Ridgeline Foods Dispute / VX-9 Sensors.
        *   Scope: All docs regarding VX-9 dev/support from [Date 3 years ago] to present.
        *   Instructions: Suspend auto-delete (Slack, personal apps). Preserve telemetry. Do not delete email/files. Contractors included.
        *   Acknowledgment form attached/implied.
        *   Contact: Litigation Counsel.

    *   *Memo:*
        *   To: General Counsel.
        *   Subject: Immediate Preservation Actions Required.
        *   List:
            1.  Marcus Bell Laptop (IT) - Friday COB.
            2.  Shared Drive Cleanup (IT) - Tonight/Saturday.
            3.  Slack Retention Override (Admin) - Immediate/48 hrs.
            4.  Personal App Forensics (IT/Eng) - Immediate.
            5.  Vendor Ticket Retention (Support) - Immediate.
            6.  Telemetry Snapshot (QA/IT) - Immediate.
        *   Most Critical: Bell Laptop. Reason: Scheduled destruction imminent.

    *   *Refining for constraints:*
        *   Ensure the Hold Notice explicitly mentions the prohibition on self-selection regarding personal devices (they can't just decide what to save, we need to collect/suspend). Actually, the hold notice tells *them* not to delete. The memo tells IT how to stop systems. The rule says "Relying on interested custodians to select what to keep is not a reasonable step." So the Hold Notice should instruct them to preserve *everything* relevant and NOT curate, and IT must suspend deletion policies.
        *   Ensure Memo highlights ownership.

    *   *Word Count Check:*
        *   Hold Notice: Aim for ~400-500 words.
        *   Memo: Aim for ~300-350 words.

6.  **Final Polish:**
    *   Check specific facts: VX-9, 3 years, Sara Okafor, Fenwick, Slack 45 days, Telemetry 21 days, Bell Friday, Shared Drive Weekend.
    *   Ensure no liability admission ("threatening suit", "dispute" vs "liability").

    *(Self-Correction during drafting)*: In the Hold Notice, I need to make sure I don't accidentally admit we owe $3.4M. Use "Dispute with Ridgeline Foods regarding VX-9 sensors".
    In the Memo, ensure I specify *why* Bell's laptop is critical.

    *Let's write.*

    **Hold Notice Draft:**
    Header. To: All Engineering Staff (including Sara Okafor), QA, Sales/Support, Contractors (Fenwick).
    Body: We have received notice of potential litigation. Duty to preserve. Scope: VX-9 sensor design, testing, support. Date: [Date 3 yrs ago] - Present.
    Systems: Email, Slack, Jira, Git, Shared Drive, Test Bench, Personal Devices (Messaging App).
    Instructions: Do not delete. Suspend auto-delete features on personal apps used for work. Contractors must comply.
    Acknowledgement required by EOD.

    **Memo Draft:**
    To: GC. From: Counsel. Re: Preservation Actions.
    Urgency Order:
    1. Marcus Bell Laptop (IT). Deadline: Thursday 5PM (before Friday reimage).
    2. Shared Drive Purge (IT Security). Deadline: Today/Weekend.
    3. Telemetry Snapshot (QA/IT). Deadline: Immediate.
    4. Slack Retention Change (Admin). Deadline: 2 Days.
    5. Vendor Ticket Freeze (Support Lead). Deadline: 3 Days.
    Most Critical: Bell Laptop. Hard deadline imminent, data loss irreversible.

    *Wait, check word counts carefully.*
    Hold Notice limit 600.
    Memo limit 400.

    *Revised Plan:*
    Make the Hold Notice concise but comprehensive on sources.
    Make the Memo very direct.

    *Specific Fact Check:* "Marcus Bell... laptop is scheduled for standard reimaging and reissue this Friday." Today is presumably Monday/Tuesday ("Facts gathered this morning", "Yesterday Trellick received"). So deadline is Friday.
    "Spring cleanup... this weekend."
    "Personal-phone messaging app configured to auto-delete messages after one week."

    *Most Time Critical:* Marcus Bell's laptop (Friday) vs Shared Drive (Weekend). Laptop is usually sooner in a work week context if today is Monday/Tuesday. Let's assume "This morning" is Tuesday, Friday is 3 days away. Weekend is 5 days away. So Bell is more critical. Also personal data on company hardware is higher risk for spoliation sanctions if not secured immediately upon resignation.

    *Hold Notice Detail:* Must explicitly mention the personal messaging app because of Rule 2 (info held by employees on personal devices used for work). Must mention contractors (Rule 2 - third parties acting for company). Must prohibit reliance on self-selection (Rule 3 implication - hold says preserve all, don't filter).

    *Let's finalize text.*
