Comment by PatentlyDC123

The Federal Rules of Evidence define a "writing" as consist[ing] of letters, words, numbers, or their equivalent set down in any form. The litigation hold most likely defined the writings that should be retained similarly. "Any form" is purposefully chosen in the definition to capture as much as possible. Typically such terms are defined broadly under the reasoning that the court wants to preserve most evidence for trial. The parties can make arguments later as to whether a document is privileged or not.