Using part 1's definition of identification (locating potential sources and the criteria for selecting potentially relevant ESI), a main aim is usually to find the key departments, individuals, custodians and ESI locations or sources that can reasonably lead to potentially relevant information on the subject matter. To do this an organization has to be able to: understand the nature of the subject matter; identify the individuals who may hold or know relevant information; know which ESI sources are likely to contain it; identify potentially relevant information with accuracy suited to the circumstances; do so within a time frame consistent with the overall discovery objectives; and do all of this with resources proportionate to what is at stake in the matter.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.