Let's start with WE ARE NOT LAWYERS. The documents listed below are examples might help guide you. Read them carefully. Make the appropriate changes. Don't trust their accuracy, because, you may have noticed the comment above that WE ARE NOT LAWYERS.
Proposed Amendments to Federal Rules of Civil Procedure
Case Law Citations by Case
Example Findings Report
Example of Court Protective Order for Forensic Imaging
Example of Preservation Letter 01
Example of Preservation Letter 02
NDA Template
Outline for Attorney's Guide to Forensic Discovery
Preparation Notes for IT Manager Deposition
Preservation of Evidence Spoliation Warning Letter to Opposing Counsel, with optional language
Questions to Prepare for Forensic Discovery on Plaintiff
Sample 30_b__6_ deposition notice
Sample Interrogatories
Spoliation Letter with Optional Discovery Request to Opposing Counsel