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Users can manually purge items from the Recoverable Items folder.

Litigation hold doesn't affect users' day-to-day e-mail workflow, so users can continue to modify and delete mailbox items as they normally would. When a mailbox is put on litigation hold, the Recoverable Items folder isn't purged and items in this folder are retained indefinitely. Items in the Recoverable Items folder are retained for 14 days by default and then purged by Microsoft Exchange. Permanently deleted items are copied to a subfolder called Deletions in the Recoverable Items folder. When a user deletes messages from their Deleted Items folder or uses Shift+Delete to permanently delete a mailbox item, the deleted items are copied to a hidden folder in the user's mailbox.