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E-Discovery Social Media and Document
Discovery Basics Presented by:
David Rohde, J.D., LL.M. March 11, 2013
Epiq Proprietary and Confidential
Objectives
• What you need to need to know about your employees use of corporate email, social media, and the Internet
• What it means when responding to regulatory and litigation demands
• Changes in the law and rules and how effective policies and processes can mitigate risk, lower costs, and give you greater control over both your brand and the information entrusted to your care
• Relate your role to the overall litigation context • Understand the legal realities around eDiscovery
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Objectives--Approach
• Litigation/Regulatory Framework – Context – Process – Costs
• Litigation Readiness – Risk management/mitigation – Concrete steps
• Social Media – What – Where – Why – Risks – Unknowns
Epiq Proprietary and Confidential 3
THE LITIGATION PROCESS
• Process: – Complaint – Motion to Dismiss – Answer – Discovery –
• Fact Discovery – Document Production – Depositions – Witness Interviews
– Motions for Summary Judgment – Pretrial Motions – Jury Selection – Trial
Epiq Proprietary and Confidential 4
The Right to Electronic Discovery: Background
Courts • Federal Rules of Civil Procedure
– Effective December 1, 2006 – Impose significant obligations on clients and counsel
• State courts adopting new rules – Most modeled after the Federal Rules
• The right to electronic discovery is not new • “It is black letter law that computerized data is
discoverable.” Anti-Monopoly v. Hasbro, 1995 WL 649934 (S.D.N.Y. 1995).
• “[P]arties and their counsel are fully on notice of their responsibility to preserve and produce electronically stored information.” Zubulake v. UBS Warburg L.L.C., 229 F.R.D. 422, 440 (S.D.N.Y. July 20, 2004) ( “Zubulake V”).
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Federal Rules of Civil Procedure: Electronically Stored Information (ESI)
• The 2006 Amendments to F.R.C.P introduced the term “electronically stored information”
• The Advisory Committee Notes further indicate that Rule 34(a)(1) "is expansive and includes any type of information that is stored electronically," and that it "is intended to be broad enough to cover all current types of computer-based information, and flexible enough to encompass future changes and development."
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Disclosures and Discovery
26. Duty to Disclose; General Provisions Governing Discovery 27. Depositions to Perpetuate Testimony 28. Persons Before Whom Depositions May Be Taken 29. Stipulations Regarding Discovery Procedure 30. Deposition by Oral Examination 31. Depositions by Written Questions 32. Using Depositions in Court Proceedings 33. Interrogatories to Parties 34. Producing Documents, Electronically Stored Information, and
Tangible Things, or Entering onto Land, for Inspection and Other Purposes
35. Physical and Mental Examinations 36. Requests for Admission 37. Failure to Make Disclosures or to Cooperate in Discovery;
Sanctions Epiq Proprietary and Confidential 7
Discovery Process
Epiq Proprietary and Confidential 8
Information Management
“Document retention policies, which are created in part to keep certain information from getting into the hands of others, including the Government, are common in business . . . It is, of course, not wrongful for a manager to instruct his employees to comply with a valid document retention policy under ordinary circumstances.” Arthur Andersen v. U.S., 125 S.Ct. 2129, 2135 (U.S. May 31, 2005).
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Cost of Not Managing Information
• The costs of finding information are among the largest uncontrolled costs in any business
• Knowledge workers can spend up to 40% of their time looking for the right information with which to do their job
• Records and Information Management services transform a organization’s competitive agility and responsiveness in all of its relationships
Source: Association of Corporate Counsel
Business Objective—Policy, Process, Practice
The objective of creating and implementing a Records Management and Legal Hold Program is to: • manage information from creation to disposition, maintaining only
so much information as is required or necessary to fulfill the Enterprise’s legal, regulatory, and business purposes
The culture of continuing retention in and “business as usual” despite new policies…or even new technologies
•
Vs.
Discovery Plan—EDRM Model
• Identification: • Locating potential sources of ESI & determining its scope,
breadth & depth.
• Preservation: • Ensuring that ESI is protected against inappropriate alteration
or destruction.
• Collection: • Gathering ESI for further use in the electronic discovery
process.
• Processing: • Reducing the volume of ESI and converting it, if necessary, to
forms more suitable for review & analysis. Epiq Proprietary and Confidential 12
Discovery Plan (Contd.)
• Review: • Evaluating ESI for relevance & privilege.
• Analysis: • Evaluating ESI for content & context, including key patterns,
topics, people & discussion.
• Production: • Delivering ESI to others in appropriate forms & using
appropriate delivery mechanisms.
• Presentation: • Displaying ESI before audiences (Trial, Hearings, Depositions
and Appeal).
Epiq Proprietary and Confidential 13
Three Most Important Rules of Discovery #1
Rule #1
The Standard is . . .
REASONABLE
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Three Most Important Rules of Discovery #2
Rule #2 Federal Rule of Civil Procedure 1: These rules govern the procedure in all civil actions and proceedings in the United States district courts . . . They should be construed and administered to secure the just, speedy, and inexpensive determination of every action and proceeding.
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Three Most Important Rules of Discovery #3
Rule #3 Federal Rule of Civil Procedure 26(b)(1) (Scope in General): Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any non-privileged matter that is relevant to any party's claim or defense — including the existence, description, nature, custody, condition, and location of any documents or other tangible things and the identity and location of persons who know of any discoverable matter. For good cause, the court may order discovery of any matter relevant to the subject matter involved in the action. Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence. All discovery is subject to the limitations imposed by Rule 26(b)(2)(C).
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Epiq Proprietary and Confidential 17
If a litigation involves discovery,
55-90%
of the money spent will be on discovery
Discovery Costs $$$
Information Explosion
Epiq Proprietary and Confidential 18
ESI Volume
Epiq Proprietary and Confidential 19
Email • 1.5 GB Lotus Notes (NSF file) is 13,500 emails and 4,500 attachments
GB • 1 GB is about 75,000 pages (pick-up truck full of documents)
Email Average
• Average # of pages in an email is 1.5 (100,099 pages per GB)
Word • Average # of pages per Word document is 8 (64,782 pages per GB)
Spread sheet
• Average # of pages per spreadsheet is 50 (165,791 pages per GB)
Power Point
• Average # of pages per PowerPoint file is 14 (17,552 pages per GB)
CD ROM • Average # of pages on a CD ROM is 32,500 (650 MB)
Defining Electronic Discovery: All Discovery includes E-Discovery
“The Motion has been made and seconded that we stick our heads in the sand.”
Epiq Proprietary and Confidential 20
ESI is Not Paper
How is ESI Different than paper discovery? • Over 99% of new information stored in the
United States is stored electronically • ESI is different than paper
– Persistent (“delete” is a misnomer) – Dynamic (easily changed/damaged) – Ubiquitous (copies can exist in many places at
once) • Volume is the enemy • Not understanding what you are agreeing to can be
costly
Epiq Proprietary and Confidential 21
Defining Electronic Discovery: Types of E-Discovery
• E-mails • Instant Messages • Word processing documents • Faxes • Voice mails • Digital Images and Graphics • Internet usage history • Deleted, Fragmentary and Residual Data • Spreadsheets • Drawing Files (CAD, Engineering, Scientific) • Databases and Websites • Video – YouTube, Security Cameras, Web and Video
Conferences • GPS Data
Epiq Proprietary and Confidential 22
Defining Electronic Discovery: Sources of E-Discovery
• Computer Hard Drives • Company Servers/Network Storage Devices • PDAs and SmartPhones (BlackBerry/iPhone/Android, etc.) • CDs, DVDs, External Hard drives • USB Removable Drive/Memory Sticks/Flash Drives • I-Pods • GPS Units • Disaster Recovery Sites • Off-Site Storage • Employees’ Homes - including kitchens, car trunks, mini-
warehouses, etc. • Third-Parties – e.g., application service providers • Social Networking Sites – Facebook, Twitter and Second Life
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E-Discovery and Document Discovery
Preservation
Epiq Proprietary and Confidential
Preservation
Preservation - Assume Everything You Write At This Point Will Be on The Cover of the NY Times!
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Preservation
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Preservation: Trigger
In litigations or investigations, there is something called a Duty to Preserve. Technically, this means a party should start preserving all information as soon as they “reasonably anticipate” the litigation or investigation. When that duty is “triggered” is the subject of a large body of case law, for example: “The duty to preserve material evidence arises not only during litigation but also extends to that period before the litigation when a party reasonably should know that the evidence may be relevant to anticipated litigation.” Silvestri v. General Motors Corp., 271 F.3d 583, 591 (4th Cir. 2001). “The mere existence of a dispute does not necessarily mean that parties should reasonably anticipate litigation or that the duty to preserve arises.” Goodman v. Praxair Services, Inc., 632 F. Supp. 2d 494 (D. Md. 2009) (J. Grimm). Epiq Proprietary and Confidential 27
Preservation: Trigger
Knowing when that “trigger” happens is a pain point for many lawyers – they consider: • The kind of complaint or threat; • The party making the claim; • The business relationship between the accused and accusing parties; • Whether the party making the claim is known to be aggressive or litigious; • The likely strength of a potential claim; • The likelihood that data relating to a claim could be lost or destroyed; • The significance of the data to the known or reasonably anticipated
issues; • Whether the company has learned of similar claims; • The experience of the industry; and • Whether the relevant records might be being retained for some other
reason.
Epiq Proprietary and Confidential 28
Preservation: Who
Does the company have to keep every single document from every employee? NO The duty to preserve extends to those employees likely to have relevant information -- the "key players" in the case. Zubulake IV, at 217-218.
Epiq Proprietary and Confidential 29
Preservation: What
.
Does the company need to keep every single document from a key player? NO The company only has to keep those documents that are relevant to the “claims, defenses, counter claims, damages, mitigation, or impeachment” in the case.
Practical Point: Because it is often hard to know what will be important, many clients engage vendors to collect the entire hard drive, network drive etc. for key players so they know it is preserved.
Epiq Proprietary and Confidential 30
Preservation: What
.
Computers and network drives are considered “accessible” and will probably always have to be collected and reviewed – but what about data that is not so easy to get (e.g., backup tapes, old mainframe data)?
The rules have an exception for “Inaccessible Data” As a general rule, the litigation hold does not apply to inaccessible data like backup media(e.g., those typically maintained solely for the purpose of disaster recovery) BUT, if backup media are actively used for information retrieval, they are no longer “inaccessible.”
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Preservation
Responsible Persons • “[T]he obligation to preserve evidence runs first to
counsel, who then has a duty to advise and explain to the client its obligations to retain pertinent documents that may be relevant to the litigation.” Telecom Int’l Am., Ltd. v. AT&T Corp., 189 F.R.D. 76, 81 (S.D.N.Y. 1999)
• Courts have found that obligation to preserve runs also to senior corporate officers. In re Prudential Ins. Co. of Am. Sales Practices, 169 F.R.D. 598 (D.N.J. 1997)
Epiq Proprietary and Confidential 32
Preservation: How?
Because there are many ways to manage electronic data, and the data exists in so many locations (laptop, cell phone, iPad), parties can choose the best preservation method for the case Practical Point: Many companies choose to COLLECT the data and hold at a vendor or a secure server in the company so they can be sure it won’t go missing.
Epiq Proprietary and Confidential 33
Preservation: How?
Use Litigation Hold Notices: • Key People and IT Personnel • Explain Case • Explain Relevant Information in normal language (No
Legalize) and be brief • Explain Where Information Could Be • Explain HOW to Preserve • Remind Employees to Keep Litigation Confidential • Have a Single Point of Conduct (SPOC) • Track Who Got The Holds and What Version • Do not ask employees to preserve information without telling
them how (or if they cannot)! (e.g. voicemail)
Epiq Proprietary and Confidential 34
Preservation: Potential Problems . . .
A. Leavers and Changers
B. Deleted, Fragmentary or Residual Data
C. Legacy Data
D. Social Media
E. Voice Mail
F. Email and IM’s
G. Third Parties (accountants, sub contractors, lawyers, etc.)
Epiq Proprietary and Confidential 35
Federal Rules: Sanctions Safe Harbor
Rule 37(e). Failure to Make Disclosures or Cooperate in Discovery; Sanctions. Electronically Stored Information. • “Absent exceptional circumstances, sanctions cannot
be imposed for loss of electronically stored information resulting from the routine, good faith operation of an electronic information system” – Must show information was lost by routine operation
of an information system – Must show that the operation was in good faith
E.g., intervention to modify or suspend some features of a system’s routine operation to prevent the loss of information that is subject to a preservation obligation
Epiq Proprietary and Confidential 36
E-Discovery and Document
Discovery Basics
COLLECTION
Epiq Proprietary and Confidential
Collection
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Collection
• Hold in place – May be initially viewed as least costly
• Considerations include: – Feasibility – Number of custodians – Type of data – Nature of complaint – Duration of hold – Custodial self-preservation concerns
• Collect to preserve – Cost and burden – Potential for over/under preservation – Difficult to manage in “ongoing” preservations
Epiq Proprietary and Confidential 39
Collection Options
Determine Collection Methodology
• Overview of collection methods – Forensic copy: A forensic copy is an exact copy
of the entire physical storage media. Forensically-sound: A copy of the reasonably accessible data contained in an information repository, accomplished using appropriate tools
– Self Collection: Relies upon an individual to locate and transfer information from an information repository to the requesting party
– Third-party: Relies on a vendor to collect – Internal IT Resources: relies on your IT resources to
execute on the collection plan Epiq Proprietary and Confidential 40
E-Discovery and Document Discovery
Sanctions
Epiq Proprietary and Confidential
Learning the Hard Way
Epiq Proprietary and Confidential 42
Sanctions
Sanctions for Violating Preservation Obligations • Adverse inference sanction, allowing jury to infer that deleted emails
contained evidence harmful to defendant; directly leads to verdict in excess of $29 million. Zubulake V
• Court strikes defendant’s answer and enters judgment for plaintiff on issue of liability, where defendant reformatted computer hard drive a day before court-ordered inspection. QZO, Inc. v. Moyer, 594 S.E.2d 541 (S.C. Ct. App. 2004)
• Court enters judgment in plaintiff’s favor on issue of liability where defendants failed to produce e-mail and electronic documents and failed to preserve computer hard drives. Metropolitan Opera Ass’n v. Local 100, 212 F.R.D. 178 (S.D.N.Y. 2003).
Epiq Proprietary and Confidential 43
Sanctions
Sanctions for Violating Preservation Obligations Contd. • 9th Circuit upholds dismissal, finding that plaintiff’s “behavior
amounted to willful spoliation because he knew he was under a duty to preserve all data on the laptop, but intentionally deleted many files and then wrote a program to write over deleted documents.” Leon v. IDX Sys. Corp., 2006 WL 2684512 (Sept. 20, 2006).
• Court dismisses wrongful termination claim because employee intentionally deleted documents on his home computer after receiving notice he may be required to produce it. Plasse v. Tyco Corp., 2006 WL 262344 (D. Mass Sept. 7, 2006).
Epiq Proprietary and Confidential 44
Statistics
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5% 95%
Social Media…it’s everywhere your staff wants to be
Preliminary Issues
• Existence of a Social Media Policy
• Standard Contract Terms of Social Networking Sites
• Healthcare Content on a Third-Party Site
• Labor Relations Issues
• Use of Social Media in Hiring Decisions
• Does Your Social Media Policy Reach *ALL* Employee Conduct
Healthcare Industry Issues
As adapted from a recent post on David Harlow’s HealthBlawg, the key issues for consideration include the following:
•”Privacy and security rules, under HIPAA as well as other federal and state laws, and the ever-diminishing ability to fully de-identify protected health information •Professional responsibility codes, including both professional society codes of ethics and state regulations promulgated by boards of registration in medicine •Malpractice liability for professional advice rendered via social media •Liability under Federal Trade Commission rules for failure to disclose a financial relationship in conjunction with an online rating, review or other commentary •Trouble with the National Labor Relations Board if employee discussion of working conditions in unreasonably limited (even in non-union shops)”
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Specific Risks
• Lack of a Social Media Policy – Lack of employee training (both on/off clock) – Document the policy and the training
• Lack of an Organizational Use Plan – Your advertent use may be problematic if not intentionally
planned • Inadvertent posting of patient information
– Access to Social Media is most often unrestricted – Smartphones and tablets operate independent of the
organization’s infrastructure • When PHI or other sensitive information is posted, it is
unencrypted – Once posted, virtually impossible to delete; breach may
have occurred
Epiq Proprietary and Confidential 49
Examples of Use
• Employee of the Month—posts a picture holding the award certificate to Facebook—patients are identifiable in the background—Potential HIPAA violation attributable to facility
• No Good Deed Goes Unpunished—Facility creates a Facebook page and a resident posts that her condition has improved—the Facility has to be careful of its employee’s response: – Patient self-identified, but – Did not consent to an unlimited discussion of her condition
Epiq Proprietary and Confidential 50
Deleting Info from Social Media
• “Information obtained in the public domain, such as social media sites, is there forever and has the potential to be indexed endlessly in many different types of data warehouses,” said Chris Apgar, CEO and president at Apgar & Associates.
• “The risks are great and can include patient harm, lawsuits, data breaches, regulatory audit and reputational damage to your clinic or patients.” – Chris Apgar, CEO and president at Apgar & Associates
Epiq Proprietary and Confidential 51
Social Media Policy
• Coverage: – organizations should establish policies and procedures for
managing risks related to privacy, reputation management, and employment issues
• What about an employee’s use of Social Media “off-the-clock” – Problems arise when an employee uses a company-sponsored site to
post negative comments or reveal confidential/protected information
– Employers could be liable for defamatory statements made by an employee, if the person had the authority to speak on the company's behalf
• Proving “speaking authority” is still litigation
– Employees can create a hostile work environment from home, on the road, or at work
• Email • Instant Messaging • Texting/Sexting • Facebooking • Cyber-stalking
Epiq Proprietary and Confidential 52
Policy’s Reach
• From a recent NLRB Decision… • “Employees have a Section 7 right to discuss their
wages and other terms and conditions of employment.”
• “Here the Employer’s rule limits employee discussion of terms and conditions of employment to discussions conducted in an ‘appropriate’ manner, thereby implicitly prohibiting ‘inappropriate’ discussions of terms and conditions of employment.”
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Policy’s Reach
• “The policy does not define what an ‘appropriate’ or ‘inappropriate’ discussion of terms and conditions of employment would be, either through specific examples of what is covered or through limiting language that would exclude Section 7 activity.”
• “We concluded that employees would therefore reasonably interpret the rule to prohibit protected activity, including criticism of the Employer’s labor policies, treatment of employees, and terms and conditions of employment.”
Epiq Proprietary and Confidential 54
“Good Social Media Policy”
• Avoid vague and overly broad terms – “Any” and “All” without qualifiers should be used sparingly
• Provide specific examples of what is prohibited
– Sharing confidential, protected, or patient data – Trade secrets – Proprietary information – Disparagement that touches on protected classes (age,
sex, sexual orientation, race, national origin, etc.) – Harassment, threats of violence
• Include a “savings clause” – Policy does not prohibit protected conduct
Epiq Proprietary and Confidential 55
NLRB Guidance--Summary
• Social media policies should be narrowly tailored
– Work with employment counsel to tailor—likely can’t forbid: – the use of social media to post pictures – employees “making disparaging comments” or sharing wage
info or working conditions – engaging “in inappropriate discussions about the company,
management, and/or coworkers.” – employees from using the company’s name, address or other
information
• Should not prohibit “concerted activity” via social media (NLRA Section VII activities) – Vague standards, and per-case review
• Union and non-union employees alike are covered by the NLRA
Epiq Proprietary and Confidential 56
Other Social Media Considerations
• Fair Credit Reporting Act – strict rules when using information gathered from pre-employment
checks – If the social media info impacts the hiring decision the dispute
resolution process kicks in – Social media is fluid and complicates this process
• Negligent Hiring – If you find troubling info on a social network page, and you ignore it,
and later the employee acts out, it may give rise to a claim • Password Requests
– Asking for passwords to social media websites is troubling to many; – The Social Networking Online Protection Act (SNOPA), is pending in
Congress and would bar employers from requiring access to online content from applicants and current employees
– Some states have passed similar protections...
Epiq Proprietary and Confidential 57
NLRB in a Certain Amount of Limbo
• Noel Canning v. National Labor Relations Board, 12-1115, 12-1153, U.S. Court of Appeals for the District of Columbia (Washington)—challenged the validity of the “recess” appointments of NLRB members
• “The court held that Obama’s recess appointments to the U.S. National Labor Relations Board last year, made after Republicans refused to consider his nominees, were “constitutionally invalid” because the Senate wasn’t in recess at the time.” – Tom Schoenberg, Bloomberg
• Casts doubt on more than 200 NLRB decisions—including certain social media policy/use cases… Epiq Proprietary and Confidential 58
Social Media Terms and Conditions
• Indemnity: Facebook – “ If anyone brings a claims against us related to your actions or your content on Facebook, you will indemnify or hold us harmless from and against any and all damages . . . of any kind . . .”
• Dispute resolution via arbitration or court? – Up to Facebook
• Location of court (venue)? – Up to Facebook
• Which law applies(choice of law)? – Up to Facebook
Epiq Proprietary and Confidential 59
Social Media Terms and Conditions
• Changes to Terms and Conditions: – Facebook 9/08: “We reserve the right, at our sole
discretion, to change, modify, add, or delete portions of these Terms of Use at any time without further notice. . . Your continued use of the . . . Site after any such changes constitutes your acceptance of the new Terms of Use”
– Facebook 5/09: “We can change this Statement so long as we provide you notice through Facebook . . . and an opportunity to comment. . . . We can make changes for administrative or legal reasons upon notice but without opportunity to comment.”
Epiq Proprietary and Confidential 60
Social Media Claims Against the Organization
• It’s not just the regulators who may be interested in how the organization uses social media…
• Claims may be brought by employees for: – Discrimination in hiring decisions – Improper discovery of personal information – Unlawful Invasion of Privacy – Illegal Background Checks
• Maintaining appropriate disclaimers… – Patient care should not be provided via Social Media – Use disclaimers and provide only general advice and
information • Comments and Responses can be troublesome!
Epiq Proprietary and Confidential 61
Proactive Use of Social Media
• Monitoring use and responding to complaints in the forum in which raised – Twitter and Comcast vs. Taco Bell
• Comcast proactive • Taco Bell “asleep at the wheel”
– Monitored and Deleted Posts • How a consumer’s “voice” is heard is one thing—you can
gate-keep the page if comments are open—deleting the comments because you don’t like what your reading is another…Chapstick found this out the hard way…
Epiq Proprietary and Confidential 62
ChapStick
Epiq Proprietary and Confidential 63
Where do Lost ChapSticks go? Comments deleted… Butt Seriously ChapStick FB page is born…
Insurance
• Once your have engaged in the use of Social Media channels, consider reviewing or obtaining Employment Practices Liability Insurance
– If you have it, review the policy for terms of coverage
– If you don’t have it…consider getting it!
Epiq Proprietary and Confidential 64
Email and Instant Messaging
• Use is integral to business • Some ERM systems link to email for workflow • Portability of access and separating work from
personal accounts – BYOD (Bring Your Own Device) – Security and HIPAA regulations – Loss and ability to wipe – Use for unintended purposes
• From Sunday’s NY Post: – ‘Buff’oon teacher loses job after using school e-mail address in
personal ads – Email Lives Forever! – Informality is a pitfall (Standard & Poor and JP Morgan) – IM and Texting are even worse!
Epiq Proprietary and Confidential 65
Litigation Readiness Considerations
• Inventory of Records – Accessible and Inaccessible
• Records Retention Policy
– Audit for completeness, accuracy and compliance – Cover ESI and Social Media
• Social Media Policy
– Training – Monitoring
• Legal Hold Policy and Process
– Determine Scope of Data/Documents to be Preserved – Issue the Litigation Hold – Terminate “Routine” Operations that may destroy
data
• Discuss Impact of Preservation – Burdens/Cost/Feasibility/Duration
• Communicate with third-parties
– Employees – Counsel – Vendors
Epiq Proprietary and Confidential 66
Q & A
David D. Rohde, JD, LL.M. Senior Director, Consulting Epiq eDiscovery Solutions 917.399.7771 – mobile