Civil Litigation 7th Edition (Kerley, Hames, & Sukys), Chapter 8, page 268 -> THE DOUGLASS FINANCIAL SERVICES INC. CASE - Assignment for Chapter 8: Identifying ESI

The case is about to proceed to the discovery phase. Your supervising attorney tells you that your client, Douglass Financial, Inc., will be subjected to numerous requests for ESI. Your attorney tells you to contact an individual who works in IT for your client and become familiar with how Douglass Financial utilizes technology to make databases and store data. What questions should I as when contacting the IT employee?