Discovery in modern litigation is fraught with pitfalls and perils. Sanctions are imposed for discovery violations more than any other litigation mistake. Mishandling discovery is also a leading cause of client dissatisfaction with their lawyers. Here are 15 tips to avoid the most common headaches and sanction triggers this year.

• Implement timely and effective legal holds. Be sure that a legal hold is issued as soon as litigation is filed or reasonably anticipated. Confirm that the notice is sufficiently broad, that it is sent to the right custodians and that it is updated and/or the recipient list is adjusted as further information comes to light.

• Conduct key custodian interviews. Do not count on the hold notice alone — there should be oral interviews with at least the key custodians and appropriate information-technology representatives in almost every case, to help ensure that autodelete protocols are suspended and all relevant information is identified, preserved, collected and produced when appropriate.