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Electronic Discovery

eDiscovery Project Management: “Belt and Suspenders” Approach for Effective Communication
 

eDiscovery Daily has published 57 posts to date related to Project Management principles (including this one).  Those include two excellent series by Jane Gennarelli, one covering a range of eDiscovery Project Management best practice topics from October thru December last year, and another covering management of a contract review team, which ran from January to early March this year.

Effective communication is a key part of effective project management, whether that communication is internally within the project team or externally with your client.  It is so easy for miscommunications to occur that can derail your project and cause deadlines to be missed, or work product to be incomplete or not meet the client’s expectations.

I like to employ a “belt and suspenders” approach to communication with clients as much as possible, by discussing requirements or issues with the client and then following up with documentation to confirm the understanding.  That seems obvious and many project managers start out that way – they discuss project requirements and services with a client and then formally document into a contract or other binding agreement.  However, as time progresses, many PMs start to lax in following up to document changes discussed to scope or approach to handling specific exceptions with clients.  Often, it’s the little day to day discussions and decisions that aren’t documented that can come back to haunt you. Or PMs communicate solely via email and keep the project team waiting for the client to respond to the latest email.  Unless there is a critical decision for which documented agreement is required to proceed, discussing and documenting keeps the project moving while ensuring each decision gets documented.

I can think of several instances where this approach helped avoid major issues, especially with the follow-up agreement or email.  If nothing else, it gives you something to point back to if miscommunication occurs.  Years ago, I met with a client and reviewed a set of hard copy documents that they wanted scanned, processed and loaded into a database (we had a Master Services Agreement in place to cover those services).  The client said they had “sticky notes” on the documents that they wanted.  I took the time to go through those, ask questions and verbally confirm my understanding of which documents they wanted processed.  I then documented in an email what services they wanted and the ranges of documents they requested to be processed and they confirmed the services and those documents in their response (evidently without looking too closely at the list of document ranges).

What the client didn’t know is that one of their paralegals had removed “sticky notes” from some of the documents, so I didn’t have all of the document ranges they intended to process.  When they later started asking questions why certain documents weren’t processed, I was able to point back to the email showing their approval of the document ranges to process, verifying that we had processed the documents as instructed.  The client realized the mistake was theirs, not ours, and we helped them get the remaining documents processed and loaded.  Our reputation with that client remained strong – thanks to the “belt and suspenders” approach!

So, what do you think?  Have you had miscommunications with clients because of inadequate documentation? Please share any comments you might have or if you’d like to know more about a particular topic.

eDiscovery Best Practices: Search “Gotchas” Still Get You
 

A few days ago, I reviewed search syntax that one of my clients had prepared and noticed a couple of “gotchas” that typically cause problems.  While we’ve discussed them on this blog before, it was over a year ago (when eDiscovery Daily was still in its infancy and had a fraction of the readers it has today), so it bears covering them again.

Letting Your Wildcards Run Wild

This client liberally used wildcards to catch variations of words in their hits.  As noted previously, sometimes you can retrieve WAY more with your wildcards than you expect.  In this case, one of the wildcard terms was “win*” (presumably to catch win, wins, winner, winning, etc.).  Unfortunately, there are 253 words that begin with “win”, including wince, winch, wind, windbag, window, wine, wing, wink, winsome, winter, etc.

How do I know that there are 253 words that begin with “win”?  Am I an English professor?  No.  But, I did stay at a Holiday Inn Express last night.  Just kidding.

Actually, there is a site to show a list of words that begin with your search string.  Morewords.com shows a list of words that begin with your search string (e.g., to get all 253 words beginning with “win”, go here – simply substitute any characters for “win” in the URL to see the words that start with those characters).  This site enables you to test out your wildcard terms before using them in searches and substitute the variations you want if the wildcard search is likely to retrieve too many false hits.  Or, if you use an application like FirstPass™, powered by Venio FPR™, for first pass review, you can type the wildcard string in the search form, display all the words – in your collection – that begin with that string, and select the variations on which to search.  Either way enables you to avoid retrieving a lot of false hits you don’t want.

Those Stupid Word “Smart” Quotes

As many attorneys do, this client used Microsoft Word to prepare his proposed search syntax.  The last few versions of Microsoft Word, by default, automatically change straight quotation marks ( ' or " ) to curly quotes as you type. When you copy that text to a format that doesn’t support the smart quotes (such as HTML or a plain text editor), the quotes will show up as garbage characters because they are not supported ASCII characters.  So:

“smart quotes” aren’t very smart

will look like this…

âsmart quotesâ arenât very smart

And, your search will either return an error or some very odd results.

To learn how to disable the automatic changing of quotes to smart quotes or replace smart quotes already in a file, refer to this post from last year.  And, be careful, there’s a lot of “gotchas” out there that can cause search problems.  That’s why it’s always best to be a “STARR” and test your searches, refine and repeat them until they yield expected results.

So, what do you think?  Have you run into these “gotchas” in your searches? Please share any comments you might have or if you’d like to know more about a particular topic.

LitigationWorld Pick of the Week: Could This Be the Most Expensive eDiscovery Mistake Ever?
 

We’re pleased to announce that our blog post “eDiscovery Best Practices: Could This Be the Most Expensive eDiscovery Mistake Ever?”, regarding Google’s inadvertent disclosure during its litigation with Oracle was selected as the Pick of the Week from TechnoLawyer in the November 21, 2011 issue of LitigationWorld.  LitigationWorld is a free weekly email newsletter that provides helpful tips regarding electronic discovery, litigation strategy, and litigation technology.  It’s also a great source of ideas for blog posts!  😉

In each issue, the editorial team at LitigationWorld links to the most noteworthy articles on the litigation Web published during the previous week. From these articles, they then select one as their Pick of the Week.

Thanks to the folks at TechnoLawyer for this recognition.  We appreciate it!

eDiscovery Case Law: New York Supreme Court Requires Production of Software to Review Files

The petitioner – in TJS of New York, Inc. v. New York State Dep’t of Taxation and Fin., 932 N.Y.S.2d 243 (N.Y. App. Div. Nov. 3, 2011) – brought article 78 proceeding to compel Department of Taxation and Finance to produce records that were responsive to petitioner’s request under Freedom of Information Law (FOIL) for records related to sales tax audit.  Some of the records, however, could not be reviewed without a copy of the Department’s Audit Framework Extension software, which the Department refused to provide.  The petitioner then moved to compel production of the software program in order to install it on his computer and view the electronic files. The court denied petitioner’s motion, concluding that the software program was exempt from disclosure and also denied the petitioner’s subsequent motion to renew.

The court determined that the term “record” was broadly defined as “any information kept, held, filed, produced or reproduced by, with or for an agency …, in any physical form whatsoever, including, but not limited to, reports, statements, examinations, memoranda, opinions, folders, files, books, manuals, pamphlets, forms, papers, designs, drawings, maps, photos, letters, microfilms, computer tapes or discs, rules, regulations or codes”.  However, the petitioner disagreed, “citing the Department’s own description of the software as well as advisory opinions in which the Committee on Open Government concludes that software can constitute a record under FOIL”.

The court agreed with that argument, noting:

  • “The description of the software submitted by the Department and the reasoning and analysis contained in the advisory opinions relied on by petitioner lead us to conclude that the software at issue contains information and, thus, constitutes a record for FOIL purposes.”
  • “Specifically, the affidavit submitted by the Department from an auditor involved in the design and development of the software program, as well as the attached training manual for the software, reveals that the software is the means for conducting an audit and that, based on data entered by an auditor, the program does reconciliations, creates letters, produces forms, determines taxes due or refunds owed and creates a comprehensive audit report.  The June 1998 advisory opinion cited by petitioner concludes that software that enables an agency to manipulate data is a record pursuant to FOIL in the same way that a written manual describing a series of procedures would be subject to disclosure under FOIL”.
  • “The 2001 advisory opinion references a definition of software as ‘a series of instructions designed to produce information that can be seen on a screen, printed, stored, transferred and transmitted’ and concludes that it is a record subject to FOIL”
  • “Given these opinions and the Department’s own description of the capabilities of the program, we conclude that it is more than just a delivery system or data warehouse and, instead, falls within FOIL’s broad definition of a record subject to disclosure”

So, what do you think?  Should producing parties be required to produce specialized software to review produced records? Please share any comments you might have or if you’d like to know more about a particular topic.

eDiscovery Best Practices: When Preparing Production Sets, Quality is Job 1
 

OK, I admit I stole that line from an old Ford commercial… 😉

Yesterday, we talked about addressing parameters of production up front to ensure that those requirements make sense and avoid foreseeable production problems well before the production step.  Today, we will talk about quality control (QC) mechanisms to make sure that the production is complete and accurate.

Quality Control Checks

There are a number of checks that can and should be performed on the production set, prior to producing it to the requesting party.  Here are some examples:

  • File Counts: The most obvious check you can perform is to ensure that the count of files matches the count of documents or pages you have identified to be produced.  However, depending on the production, there may be multiple file counts to check:
    • Image Files: If you have agreed with opposing counsel to produce images for all documents, then there will be a count of images to confirm.  If you’re producing multi-page image files (typically, PDF or TIFF), the count of images should match the count of documents being produced.  If you’re producing single-page image files (usually TIFF), then the count should match the number of pages being produced.
    • Text Files: When producing image files, you may also be producing searchable text files.  Again, the count should match either the documents (multi-page text files) or pages (single-page text files) with one possible exception.  If a document or page has no searchable text, are you still producing an empty file for those?  If not, you will need to be aware of how many of those instances there are and adjust the count accordingly to verify for QC purposes.
    • Native Files: Native files (if produced) are typically at the document level, so you would want to confirm that one exists for each document being produced.
    • Subset Counts: If the documents are being produced in a certain organized manner (e.g., a folder for each custodian), it’s a good idea to identify subset counts at those levels and verify those counts as well.  Not only does this provide an extra level of count verification, but it helps to find the problem more quickly if the overall count is off.
    • Verify Counts on Final Production Media: If you’re verifying counts of the production set before copying it to the media (which is common when burning files to CD or DVD), you will need to verify those counts again after copying to ensure that all files made it to the final media.
  • Sampling of Results: Unless the production is relatively small, it may be impractical to open every last file to be produced to confirm that it is correct.  If so, employ accepted statistical sampling procedures (such as those described here and here for searching) to identify an appropriate sample size and randomly select that sample to open and confirm that the correct files were selected, HASH values of produced native files match the original source versions of those files, images are clear and text files contain the correct text.
  • Redacted Files: If any redacted files are being produced, each of these (not just a sample subset) should be reviewed to confirm that redactions of privileged or confidential information made it to the produced file.  Many review platforms overlay redactions which have to be burned into the images at production time, so it’s easy for mistakes in the process to cause those redactions to be left out or burned in at the wrong location.
  • Inclusion of Logs: Depending on agreed upon parameters, the production may include log files such as:
    • Production Log: Listing of all files being produced, with an agreed upon list of metadata fields to identify those files.
    • Privilege Log: Listing of responsive files not being produced because of privilege (and possibly confidentiality as well).  This listing often identifies the privilege being asserted for each file in the privilege log.
    • Exception Log: Listing of files that could not be produced because of a problem with the file.  Examples of types of exception files are included here.

Each production will have different parameters, so the QC requirements will differ, so there are examples, but not necessarily a comprehensive list of all potential QC checks to perform.

So, what do you think?  Can you think of other appropriate QC checks to perform on production sets?  If so, please share them!  As well as any comments you might have or if you’d like to know more about a particular topic.

eDiscovery Best Practices: Production is the “Ringo” of the eDiscovery Phases
 

Since eDiscovery Daily debuted over 14 months ago, we’ve covered a lot of case law decisions related to eDiscovery.  65 posts related to case law to date, in fact.  We’ve covered cases associated with sanctions related to failure to preserve data, issues associated with incomplete collections, inadequate searching methodologies, and inadvertent disclosures of privileged documents, among other things.  We’ve noted that 80% of the costs associated with eDiscovery are in the Review phase and that volume of data and sources from which to retrieve it (including social media and “cloud” repositories) are growing exponentially.  Most of the “press” associated with eDiscovery ranges from the “left side of the EDRM model” (i.e., Information Management, Identification, Preservation, Collection) through the stages to prepare materials for production (i.e., Processing, Review and Analysis).

All of those phases lead to one inevitable stage in eDiscovery: Production.  Yet, few people talk about the actual production step.  If Preservation, Collection and Review are the “John”, “Paul” and “George” of the eDiscovery process, Production is “Ringo”.

It’s the final crucial step in the process, and if it’s not handled correctly, all of the due diligence spent in the earlier phases could mean nothing.  So, it’s important to plan for production up front and to apply a number of quality control (QC) checks to the actual production set to ensure that the production process goes as smooth as possible.

Planning for Production Up Front

When discussing the production requirements with opposing counsel, it’s important to ensure that those requirements make sense, not only from a legal standpoint, but a technical standpoint as well.  Involve support and IT personnel in the process of deciding those parameters as they will be the people who have to meet them.  Issues to be addressed include, but not limited to:

  • Format of production (e.g., paper, images or native files);
  • Organization of files (e.g., organized by custodian, legal issue, etc.);
  • Numbering scheme (e.g., Bates labels for images, sequential file names for native files);
  • Handling of confidential and privileged documents, including log requirements and stamps to be applied;
  • Handling of redactions;
  • Format and content of production log;
  • Production media (e.g., CD, DVD, portable hard drive, FTP, etc.).

I was involved in a case recently where opposing counsel was requesting an unusual production format where the names of the files would be the subject line of the emails being produced (for example, “Re: Completed Contract, dated 12/01/2011”).  Two issues with that approach: 1) The proposed format only addressed emails, and 2) Windows file names don’t support certain characters, such as colons (:) or slashes (/).  I provided that feedback to the attorneys so that they could address with opposing counsel and hopefully agree on a revised format that made more sense.  So, let the tech folks confirm the feasibility of the production parameters.

The workflow throughout the eDiscovery process should also keep in mind the end goal of meeting the agreed upon production requirements.  For example, if you’re producing native files with metadata, you may need to take appropriate steps to keep the metadata intact during the collection and review process so that the metadata is not inadvertently changed. For some file types, metadata is changed merely by opening the file, so it may be necessary to collect the files in a forensically sound manner and conduct review using copies of the files to keep the originals intact.

Tomorrow, we will talk about preparing the production set and performing QC checks to ensure that the ESI being produced to the requesting party is complete and accurate.

So, what do you think?  Have you had issues with production planning in your cases?  Please share any comments you might have or if you’d like to know more about a particular topic.

eDiscovery Case Law: Produced ESI Doesn’t Need to be Categorized, Even When Voluminous

In United States v. Rubin/Chambers, Dunhill Ins. Servs., No. 09 Cr. 1058, (S.D.N.Y. Nov. 4, 2011), defendants’ motion to have the Government in a criminal antitrust conspiracy case organize and format its discovery production to indicate which of four categories of collusion each document or electronic file related to was denied. The Government was “under no general obligation to identify or sort Brady material within even an extremely voluminous disclosure.”

Defendants were charged with conspiring to rig bids and fix prices on municipal derivatives. They asked for an order requiring the Government “to produce discrete collections of documents and electronic files that relate to four categories of transactions, and that such production be organized and formatted so as to indicate to which of those four categories each document or electronic file relates.” Defendants contended that the categories correlated to different aspects of the Government’s theory of collusion and that the categorization of overt acts that the Government was expected to prove at trial “would be useful to impeach the testimony of cooperating witnesses who will testify as to Defendants’ intent in entering into the Featured Transactions.”

The court denied defendants’ motion. Brady materials already produced to defendants in mostly searchable format did not have to be produced again “in categorized batches” relating “to transactions with certain characteristics.” The court stated: “Absent prosecutorial misconduct — bad faith or deliberate efforts to knowingly hide Brady material — the Government’s use of ‘open file’ disclosures, even when the material disclosed is voluminous, does not run afoul of Brady.” While the court acknowledged its discretion regarding defendants’ motion, the Government had provided searchable electronic documents, defendants had corporate assistance and could assist in their own defense since they were not being incarcerated before trial, and each defendant was represented by “prominent, sophisticated counsel.” The collapse of the law firm serving as the technical coordinator for the defendants’ discovery review platform “while unfortunate, does not alter the inescapable conclusion here: Defendants are anything but impoverished and certainly not so incapacitated as to warrant shifting such a substantial portion of the burden of preparing their defense to the Government.”

So, what do you think?  Was that an appropriate ruling, given the volume of ESI?  Please share any comments you might have or if you’d like to know more about a particular topic.

Case Summary Source: Applied Discovery (free subscription required).  For eDiscovery news and best practices, check out the Applied Discovery Blog here.

Disclaimer: The views represented herein are exclusively the views of the author, and do not necessarily represent the views held by CloudNine Discovery. eDiscoveryDaily is made available by CloudNine Discovery solely for educational purposes to provide general information about general eDiscovery principles and not to provide specific legal advice applicable to any particular circumstance. eDiscoveryDaily should not be used as a substitute for competent legal advice from a lawyer you have retained and who has agreed to represent you.

eDiscovery Trends: Congress Tackles Costs and Burdens of Discovery
 

Sometimes, it does take an “act of Congress” to get things done.

On December 13, a key subcommittee of the House of Representatives will conduct hearings regarding “The Costs and Burdens of Civil Discovery”.  The 10-member House Constitution Subcommittee led by Chairman Trent Franks (R. AZ) will hear from various witnesses regarding these issues — the first such hearing since the rules were last updated in December 2006.

Since the new rules took effect five years ago, sanctions for discovery violations have increased exponentially. A 2010 study published in the Duke Law Journal (and reported in this blog one year ago today) found that there were more eDiscovery sanction cases (97) and more eDiscovery sanction awards (46) in 2009 than in any prior year – more than in all years prior to 2005 combined!!

The hearings were originally scheduled for earlier this month, on November 16.  According to the Lawyers for Civil Justice web site (which has not yet been updated to reflect the new hearings date), the hearings are expected to cover:

  • Scope and dimensions of the problems with the federal litigation system;
  • Costs and burdens faced by litigants particularly in the areas of preservation and discovery of information;
  • The impact of those costs and burdens on the American economy and the competitiveness of American companies;
  • The magnitude of the cost savings that would better be spent on improving products and services and creating jobs; and
  • Expressions of support for the Judicial Conference Committee on Practice and Procedure’s primary responsibility to develop rule based solutions that would help relieve some of those costs and burdens, increase efficiency, and improve access to the federal court system (more on their recent efforts and meeting here).

Scheduled witnesses include:

  • Rebecca Love Kourlis, former Colorado Supreme Court Justice, now Director of the Institute for the Advancement of the American Legal System;
  • William H.J. Hubbard, Assistant Professor of Law. University of Chicago Law School;
  • Thomas H. Hill, Senior Executive Counsel, Environmental Litigation & Legal Policy, General Electric Company; and
  • William P. Butterfield, Hausfeld LLP, plaintiff class action counsel.

According to the International Data Corporation (IDC), the amount of digital information created, captured and replicated in the world as of 2002 was 5 exabytes (5 billion gigabytes), rising to 988 exabytes by 2010 (nearly a 20,000% increase)!  As a result, expenses associated with storing, collecting, searching and producing ESI in discovery have skyrocketed and many say that changes to the Federal Rules are inevitable (though some say it is too soon to fully grasp the impact of the 2006 Federal Rules changes).  It will be interesting to see what comes out of the hearings next month.

So, what do you think?  Do you expect major changes to the rules regarding eDiscovery, and if so, what would you like to see changed, and why?  Please share any comments you might have or if you’d like to know more about a particular topic.

eDiscovery Trends: New York Pilot Program Requires Joint Electronic Discovery Submission for Cases Involving ESI
 

On November 1, 2011, the Southern District of New York implemented a new Pilot Program for Complex Cases in "response to the federal bar's concerns about the high costs of litigating complex civil cases." The program is "designed to improve judicial case management of these disputes and reduce costs and delay" and will run for eighteen months.

Fourteen types of civil lawsuits are designated as "complex civil cases," including "stockholder's suits, patent and trademark claims, product liability disputes, multi-district litigation, and class actions." District court judges have the power to add or remove a case from the pilot, even if it does not fall in these categories.

Parties to complex cases must submit Exhibit B, Joint Electronic Discovery Submission if they believe relevant ESI that is potentially responsive to current or future discovery requests exists. In addition, parties must certify that "they are sufficiently knowledgeable in matters relating to their clients' technological systems to discuss competently issues relating to electronic discovery, or have involved someone competent to address these issues on their behalf." They must also meet and confer prior to the Rule 16 conference on preservation; methodologies for search and review; sources of ESI; limitations on the scope of production; form of production; managing privileged material, including inadvertent production, clawback and quick peek agreements, and Rule 502(d) orders; and the costs of production, cost-saving measures, and cost allocation.

So, what do you think?  Should more jurisdictions adopt such a program? Or should they wait until the results of this pilot are published?  Please share any comments you might have or if you’d like to know more about a particular topic.

Case Summary Source: Applied Discovery.  For eDiscovery news and best practices, check out the Applied Discovery Blog here.

Disclaimer: The views represented herein are exclusively the views of the author, and do not necessarily represent the views held by CloudNine Discovery. eDiscoveryDaily is made available by CloudNine Discovery solely for educational purposes to provide general information about general eDiscovery principles and not to provide specific legal advice applicable to any particular circumstance. eDiscoveryDaily should not be used as a substitute for competent legal advice from a lawyer you have retained and who has agreed to represent you.

eDiscovery Case Law: Facebook Content Discoverable Yet Again

It seems most, if not all, of the cases these days where discoverability of social media is at issue are being decided by courts in favor of the parties seeking to discover this information.  Here’s another example.

In Largent v. Reed, 2011 WL 5632688, (Pa. C.P. Franklin Co. Nov. 8, 2011) the court ruled that the plaintiff’s Facebook information was discoverable as being relevant and not privileged and ordered the plaintiff to turn over her Facebook login information to the defendant within 14 days, giving the defendant a 21-day window to inspect the plaintiff’s Facebook profile (after which she was allowed to change her password).

In this case, one of the plaintiffs claimed that a motorcycle accident caused by the defendant left her with chronic physical and mental pain. During a deposition of one of the plaintiffs, the defendant learned that she had a Facebook account and had accessed it as recently as the night before the deposition.  The defendant had reason to believe that the plaintiff had posted pictures of herself on Facebook enjoying life with her family as well as a status update about going to the gym. Accordingly, the defendant filed a Motion to Compel, demanding that the plaintiff provide her Facebook username and password to enable the defendant to demonstrate that the plaintiff’s injuries aren’t as bad as she claimed.

The defendant cited two cases where discovery of social network content was granted: Zimmerman v. Weis Markets, Inc., No. CV-09-1535, 2011 WL 2065410 (Pa. Comm. Pl. May 19, 2011) and McMillen v. Hummingbird Speedway, Inc., No. 113-2010 CD (C.P. Jefferson, Sept. 9, 2010).  The plaintiffs responded with two cases where courts denied discovery of Facebook material: Piccolo v. Paterson, No. 2009-4979 (Pa. C.P. Bucks May 6, 2011) and Kennedy v. Norfolk S. Corp., No. 100201437 (Pa. C.P. Phila. Jan 15, 2011).

The court considered the following factors in ruling for the defendant:

  • Relevancy: Since the plaintiff claimed that “she suffers from, among other things, chronic physical and mental pain” and that the defendant claimed that the plaintiff’s “formerly public Facebook account included status updates about exercising at a gym and photographs depicting her with her family that undermine her claim for damages” the court ruled that the information sought by the defendant is “clearly relevant”.
  • Privilege and Privacy: The court noted that there “is no confidential social networking privilege under existing Pennsylvania law” and that there is “no reasonable expectation of privacy in material posted on Facebook”.
  • Stored Communications Act of 1986 (SCA): While the SCA places limits on the government’s ability to compel Internet Service Providers (ISPs) to disclose information about their users, only one court has addressed whether Facebook is an entity covered by the SCA: Crispin v. Christian Audigier Inc., 2010 U.S. Dist. Lexis 52832 (C.D. Calif. May 26, 2010).  In that case, it was ruled that the information being sought directly from Facebook (and other social networking sites) was protected under the SCA, but this court ruled that the SCA does not apply in this case because the plaintiff “is not an entity regulated by the SCA.”
  • Breadth of Discovery Request: The court noted that the plaintiff’s contention that the defendant’s motion is “akin to asking her to turn over all of her private photo albums and requesting to view her personal mail” is “mistaken” as content posted on Facebook is not private.  So, such a request would not “cause unreasonable annoyance, embarrassment, oppression, burden or expense” as the cost to investigate the plaintiff’s Facebook information would be borne by the defendant.

As a result, the court ruled in favor of the defendant and ordered the plaintiff to turn over her Facebook login information to the defendant within 14 days.  Hopefully, the plaintiff doesn’t resort to tampering with the content on their Facebook page.

So, what do you think?  Assuming relevance, should all parties be required to produce social media information? Please share any comments you might have or if you’d like to know more about a particular topic.

Happy Thanksgiving from all of us at eDiscovery Daily and CloudNine Discovery!