A Checklist of practical issues that counsel should consider when preparing a motion for sanctions under Federal Rule of Civil Procedure (FRCP) 37(e) against a party who failed to preserve electronically stored information (ESI) in federal civil litigation. Specifically, this Checklist offers guidance on the applicable rules, the basic factors courts consider before imposing sanctions under FRCP 37(e), the documents a court may require counsel to file on a motion for sanctions, and how to file and serve the motion.