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If you can't get the first sentence down, get a sentence down. Who says you have to start at the beginning? Dive straight in with your arguments, then fill out the fluff later.
Regulatory Impact - the minute you have identifiable data on the shadow kit you are a lawyers dream.
Additional cost - Its going to break, you will have to pay somehow to fix it.
Anti Virus etc - they won't have any!
DR - Disastrous recovery if you don't know its there you can't back it up or replace it.
lack of process - there is a reason you do things the way you do, they aren't what effect will that have?
Flesh it out on paper, scribble ideas first then arrange them. Then start writing yes I know its old style but it works.
Don't forget to sharpen your pencils.
HTH
Always forgive your enemies; nothing annoys them so much.
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