Appendix B
Engagement letters and the direction memo
Master engagement letter for attorney-directed AI research, an addendum for an existing engagement, the direction memo, a one-page client instruction sheet, and the specialist addendum.
Founder Privilege · Companion files
The forms,
as editable files
Every template in the book, in Word and Markdown. Retyping a form out of a paperback is nobody's idea of a good evening. No email required.
Appendix C
Defending the assertion
Declaration of the directing attorney, motion to quash skeleton, a conversation-level privilege log format, and the custodian response letter to a subpoenaing party.
Appendix D
Litigation hold and preservation letters
Internal hold notice naming AI tools by product, the preservation demand to an opposing party, a twenty-minute short version, and the meet-and-confer script.
Appendix E
Discovery requests for AI conversation data
Definitions, requests for production, interrogatories, 30(b)(6) deposition topics, the non-content provider subpoena, and ESI protocol language.
Appendix F
Case law and authority
Kovel, Heppner, Cavallaro, and the offense-chapter authorities: the Stored Communications Act, Rules 34 and 37(e), and ABA Formal Opinion 512.
The documents only work if the channel does
A memo establishes the predicate. It cannot generate the record.
What an engagement letter and a direction memo cannot do on their own is produce the contemporaneous record a court asks for when privilege is challenged. That has to exist before you know which matter will need it.
These templates are starting points, not legal advice, and downloading them does not create an attorney-client relationship with Kovel or the author. Adapt them to the facts of your matter and the rules of your jurisdiction, and have licensed counsel review before filing.