For Counsel

Advising Clients on Evidence Preservation

What to tell a new client to do immediately at intake: preserving evidence, documenting a timeline, and avoiding the mistakes that undermine a case.

Why This Matters

The Evidence Problem I See Most Often

In my work as an expert witness on social media and internet defamation matters, the single biggest obstacle I run into is not a weak legal theory — it's missing evidence. Profiles get deleted. Posts get taken down. Reviews get removed by the platform or quietly edited by the person who wrote them. By the time a matter reaches me, the content that started it all is often already gone, and the common assumption that "it's probably on archive.org" turns out to be wrong far more often than attorneys expect. The Wayback Machine only has a snapshot of a page if that specific URL happened to be crawled at the right time, and most social media posts, individual reviews, and profile pages were never crawled at all.

That's why the single most valuable thing counsel can do at intake — before filing anything, before reporting content to a platform, before sending a demand letter — is instruct the client to preserve what's currently visible, right now, while it's still there. I've built this section specifically as material counsel can use directly with clients at that first meeting, drawing on what I've actually seen go wrong in matters where that instruction came too late.

Two Things to Tell Clients Immediately

Screenshots and a Timeline

1. Take Full Screenshots

Capture the entire page, including the visible URL and, where possible, the date and time. Screenshot the profile as well as the specific post, and capture any comments or engagement that add context.

2. Start a Written Timeline

A dated journal of what the client found, when, where, and who else may have seen it. This becomes just as important as the content itself once the matter is in litigation.

Step-by-Step Guidance for Clients

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