What goes in the methodology section of an interoffice memo explaining the plan of action for preserving ESI in the hypothetical scenario below. I am having trouble addressing the timetable and methodology for implementation sections of the memo.

is anyone able to help with a few examples of what might be stated in each section?

It is related to the aforementioned hypothetical scenario:

Lost Creek Engineering, LLC v. Keith Austin Weird and Artemis Energy Solutions, Inc.

All of the events and persons described in this hypothetical scenario are fictional. Any resemblance to persons, living or dead, or to business entities is purely coincidental.

This hypothetical case concerns the alleged misappropriation of intellectual property by a senior design engineer at an engineering company.

The engineer, Keith Austin Weird, worked for Lost Creek Engineering, LLC for 15 years, rising to the position of Assistant Vice-President of Engineering. Weird led the design and development of Lost Creek's very profitable Arnold line of intelligent pipeline pigs, as well as a yet-to-be-introduced line of next generation products codenamed "When Pigs Fly." Pigs, in the context of pipelines, are devices inserted into pipelines that travel with the flowing content for the purpose of conducting inspection, maintenance, product separation and other functions.

Pipeline pigs must operate under conditions of high pressure, extreme temperatures and highly corrosive conditions. Intelligent or "smart" pigs are sophisticated robots that, until now, have been required to operate autonomously because the radio-blocking "Faraday cage" character of steel pipelines and the enormous distances traversed made it infeasible for pigs to communicate with remote operators or GPS satellites.

Lost Creek's "When Pigs Fly" innovation was the pairing of its smart pigs with an accompanying drone aircraft outside the pipeline. The innovation employs proprietary technology to enable high-bandwidth, multichannel ultrasonic communications between pig and drone, allowing a distant operator to see real time data and video from the pig, obtain precise GPS coordinates and remotely control the pig.

Precise location data means that repair crews operate more efficiently and at lower cost. Real time remote control permits complex repairs to be accomplished without the risk and cost of dispatching crews and heavy equipment to distant work sites.

Weird was hired by former Lost Creek V.P. of Engineering and Development, Montgomery Bonnell in 2000. Weird reported directly to Bonnell for the decade that both worked together at Lost Creek. The two are close friends, and their families frequently socialize outside of work.

In 2010, Bonnell left Lost Creek to found Artemis Energy Solutions, Inc. in Houston. Artemis manufactures and sells pipeline telemetry products to the energy sector. Weird sought to be considered for Bonnell's position, but was told he was too valuable in his current position and encouraged to acquire some managerial seasoning. When an outsider was brought in to replace Bonnell, Weird was assured by the CEO that his desire to advance would not be forgotten.

Bonnell's replacement left Lost Creek at the start of 2015, and Weird learned that management contacted a headhunter to fill the position. With no promotion forthcoming, Weird resigned from Lost Creek on August 14, 2015.

He gave two weeks' notice and noted that, now that his kids were in college, he was heading to Houston to work for his old friend, Monty Bonnell, at Artemis Energy Solutions, Inc.

Weird participated in a required exit interview, confirmed his familiarity with all Lost Creek polices impacting departing employees, and received a generous severance package to resolve unused vacation time and other benefits.

Weird's last day at Lost Creek was August 28, 2015, and he took two weeks off before starting at Artemis. Weird joined Artemis as its Executive VP of Technology.

On December 21, 2015, Lost Creek's outside counsel, Lamar Street, sent letters to Weird and Bonnell invoking the Non-Disclosure Agreement and Covenant Not to Compete Weird signed when first hired by Lost Creek. Lost Creek demanded that Weird cease work for Artemis on anything involving pipeline pigs or telemetry.

The letter to Weird also sought return of Weird's Lost Creek laptop and access to all of Weird's personal computers, digital media and e-mail accounts for the purpose of conducting an examination to assess compliance.

Shortly after Lost Creek distributed year-end bonuses on December 23, 2015, three Lost Creek engineers, Percy Pennybacker, Claudia Johnson and Barton Springs, tendered their resignations.

All had worked under Weird at Lost Creek in the development and testing of intelligent pipeline pigs. All joined Artemis and once more report to Weird.

In February of 2016, Artemis' internal SharePoint newsletter announced that the company would be introducing the AirHog line of sophisticated intelligent pipeline drone pigs that, by the description of their capabilities, would mirror the capabilities of Lost Creek's yet-to-beintroduced When Pigs Fly technology.

The article offered rosy financial projections for the new product line, prompting a blizzard of Tweets and texts between Artemis employees, Lost Creek employees and industry insiders.

On March 1, 2016, Lost Creek filed suit against Weird and Artemis in the Western District of Texas seeking injunctive relief and damages on seven counts:

Count 1 - Breaches of Trade Secret Agreement and Covenant Not to Compete

Count 2 - Unfair Competition by Misappropriation

Count 3 - Tortious Conversion

Count 4 - Common Law Misappropriation of Trade Secrets

Count 5 - Tortious Interference with M-I's Employment Contracts

Count 6 - Breach of Fiduciary Duty

Count 7 - Civil Conspiracy The Defendants answered, asserting various affirmative defenses.

Lost Creek has been in business for 40 years. It is headquartered in Austin, Texas and maintains manufacturing sales and service centers in China, Australia and Europe, as well as representatives and technicians in more than 20 countries.

Lost Creek is a closely-held company that employs over 400 people, including 40+ persons in its Product Development and Engineering Division.

Its sales and earnings figures are not made public. Artemis Energy Solutions, Inc. was formed in 2010 and is headquartered in Houston, Texas.

Artemis employed 150 people as of April 15, 2016, and projected gross annual sales of approximately $75 million for 2016 based on first quarter results.

In May of 2016, Artemis was acquired by Prytania Oil, S.A., a conglomerate headquartered in Greece, and Artemis became a wholly-owned foreign subsidiary of Prytania Oil, S.A.

Timeline of Events

September 1, 2000: Keith Austin Weird hired by Lost Creek; executes Non-Disclosure Agreement and Covenant Not to Compete

August 12, 2015: Weird receives offer letter from Artemis and copies Lost Creek data to an external hard disk drive

August 14, 2015: Weird tenders his resignation to Lost Creek

August 28, 2015: Weird's last day at Lost Creek; exit interview

August 31 - September 11, 2015: Weird on vacation

September 14, 2015: Weird's first day at Artemis

December 2015: Three Lost Creek engineering employees quit to join Artemis

December 21, 2015: Demand for return of Weird's Lost Creek laptop and to inspect his e-mail, home systems, hard drives and thumb drives

February 1, 2016: Artemis announces forthcoming AirHog product line

March 1, 2016: Original Complaint filed

March 10, 2016: Original Answer filed

March 15, 2016: Amended Complaint Filed

March 18, 2016: Amended Answer filed

April 1, 2016: Agreed Temporary Injunction entered

May 15, 2016: Prytania Oil, S.A. acquires all shares in Artemis