E-Discovery Sample Interrogatories LH

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E-discovery Sample Interrogatories Interrogatories Regarding E-mail Systems 1.

Describe all e-mail software presently and previously used by you and the dates o off use, including including but not limited to the name of the software, and the version number in use during the relevant time period of this litigation.

2.

List all servers that are currently used or have have been used used for the e-mail system including the the server name, dates of use, and the dates of its use as an e-mail server during the relevant time period of this litigation.

3.

List any specic type of hardware that was used, during during the relevant ti time me period of this litigation, as terminals into the e-mail system (including laptops, desktops, cell phones, personal digital assistants) and its current location.

4.

Identify all past and current users on each e-mail e-mail system, during the relevant time time period of this litigation, and the location of each user’s user ’s mail les.

5.

State whether the e-mail is encrypted in any way way and list list passwords for all past past and current current users during the relevant time period of this litigation.

6.

Identify all past and current users known to you who have generated e-mail related to the subject subject matter(s) of this litigation during.

7.

Identify all e-mail known known to you you that relates relates to, references or is relevant relevant to the the subject matter of this litigation, including but not limited to, date, recipient(s) and authors.

8.

Identify all past and current persons persons responsible responsible for administering the e-mail system(s) during the the relevant time period of this litigation.

9.

Identify any mailboxes that have been restored from backup backup tape during the relevant time period of this litigation, and provide the name of the mailbox restored, the size of the mailbox restored, the resources required to perform the restoration in terms of labor hours, equipment, and drive space.

Interrogatories Regarding Computer Systems 10. State whether deletion utility utility programs are used on computer computer,, during the relevant tim timee period of this litigation, including but not limited to the name of the program(s) and the dates the program was used to permanently delete les. 11. State whether any computer hardware hardware has been upgraded during during the relevant time period o off this litigation, and describe the type of upgrade and whether the replaced parts were retained.

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14. Identify any hard drives that that were erased or reformatted for new users during the relevant time time period of this litigation, and whether they are backed up before the new user receives the computer. 15. For each of the individuals listed below, below, provide a detailed description of their computer system(s) used during the relevant time period of this litigation, including but not limited to: the brand and model of any desktop and laptop computers, personal digital assistants, cellular phones, and voice mail equipment. Include this information for any of the above-mentioned devices if they are used at home for business purposes. 16. For each of the individuals listed below, below, provide a detailed description of all software installed on any desktop and laptop computers, personal digital assistants, cellular phones, and voice mail equipment during the relevant time period of this litigation including, but not limited to: the brand and version, the operating system, any custom or commercial applications, and shareware. Include information on any of the above-mentioned software if it is used at home for business purposes. 17. For each of the individuals listed below, below, identify their communications capab capability ility during the relevant time period of this litigation, including, but not limited to: terminal to mainframe emulation, data download and/or upload capability to mainframe, and computer to computer connections via a network, modem and/or direct connection of any desktop or laptop computers, PDAs, cellular phones and voice mail equipment. Please include information on any of the above-mentioned individuals individuals if any of these devices are used at home for business purposes.

 

18. Describe each computer network network that was in use during the the relevant time period of tthis his litigation. Your description should include, but is not limited to: the brand and version number of the net work operating system currently or previously in use including the dates of all upgrades; the quantity and conguration of all network servers and workstations currently or previously in use; and the brand name and version number of all applications and other software residing on each network in use, including but not limited to electronic mail and applications. 19. Identify the current and present present persons responsibl responsiblee for the ongoing operations, operations, maintenance, expansion, archiving and upkeep of the network. 20. Describe in detail the connectivity connectivity and interface between the computer system o off _____________ at ______________ and the computer system at _______________ _______________ in __________________ __________________ including a description of the following: all possible ways in which electronic data is shared between locations; the method of transmission; the type(s) of data transferred; the names of all individuals possessing the capability for such transfer, including list and names of authorized outside users of the mail system; the individual responsible for supervising inter-connecti inter-connectivity vity.. 21. Describe the layout of the computer computer system, during during the relevant time period of of this litigation, including but not limited to, the number and types of computers, how or if they are networked, and the type(s) of operating system(s) and application software packages used. 22. Identify the following following attributes of each minimini- and mainframe computer system system used in the organization, during the relevant time period of this litigation: brand and version number of the

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operating system in use; identity of the person(s) responsible for the ongoing operation, maintenance, expansion and upkeep of the mini- and/or mainframe system; name and description of function of all application and other software residing on the network, including, but not limited to electronic mail applications. 23. Describe in detail all inter-connectivity inter-connectivity between __________ ________________ ______ and __________________. __________________. This description should include all possible ways in which electronic data is shared between organizations, the method of transmission, type(s) of data transferred and the names of all individuals possessing the capability for such transfer, including lists and names of authorized outside users of the [producing party’s] party’s] electronic mail system. 24. Provide the name, employer, employer, title, busi business, ness, address, home address and and telephone numbers of each person with operational maintenance responsibility for the day-to-day operations of plaintiffs computer systems, systems, hardware, and software during the relevant time period of this litigation.

Interrogatories Regarding Backup 25. Provide the name, employer, employer, title, busi business ness address, home address and and telephone numbers of of each person responsible for the day-to-day tasks of backing up les and archiving les and data on the plaintiffs computer systems during the relevant time period of this litigation. 26. Identify all procedures and devices devices used to back up all so software ftware and data, during the relevan relevantt time period of this litigation, including but not limited to: the name(s) of backup software used, the frequency of the backup process, tape rotation schedule, type of tape backup drives, including name and version number; and the type of media (i.e., DLT, 4mm, 8mm, AIT). 27. State the capacity and total amount amount of information stored on each tape, created during the the relevant time period of this litigation, as a result of any data back-up procedures performed on all computer systems. 28. Describe the tape or backup rotation rotation and explain ho how w backup data is maintained maintained and state whether the backups are full, incremental or differential (attach a copy of all rotation schedules). 29. Who is the individual(s) who conducts the backup and the individual who supervises this process? 30. Provide a detailed list of all backup backup tapes, regardless of the magnetic magnetic media on which they they reside, showing current location, custodian, date of backup, a description of backup content and a full inventory of all archives. 31. Identify all non-routine non-routine backups applicable for any sservers ervers identied in response response to these interrogatories, such as quarterly archival backup and yearly backups, and identify the current location of any such backups. 32. If the hard drive of any server, server, workstation, notebo notebook/laptop/deskt ok/laptop/desktop op PC (for home or work use), or any storage device or media, has been “wiped clean” or reformatted so that the information on the hard drive, storage device, or media is permanently destroyed, please provide: the date on which each drive was “wiped clean” and the method or program used (e.g., WipeDi WipeDisk, sk, WipeFile, BurnIt, Data Eraser, etc.).

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33. Identify any users who had backup backup systems for/with for/with their laptop or deskt desktop op computers, including including personal equipment used for business purposes, and describe the nature of the backup. 34. Who is responsible for maintaining maintaining the sched schedule ule of redeployment or circu circulation lation of existing equipment? 35. Describe the system or process process for redeployment of exi existing sting equipment. 36. Identify any data that has been deleted, physically dest destroyed, royed, discarded, damaged (ph (physically ysically or logically), or overwritten, whether pursuant to a document retention policy or otherwise, since the commencement of this litigation. Specically identify those documents that relate to or reference the subject matter of the above referenced litigation. 37. Identify and describe all backup backup tapes in your possession possession including: types types and number of tapes in your possession (such as DLT, AIT, Mammoth, 4mm, 8mm); capacity (bytes) and total amount of information (bytes) stored on each tape; all tapes that have been reinitialized or overwritten since commencement of this litigation and state the date of said occurrence. 38. Is backup storage media kept kept off-site? If so, provide a list list and the location of su such ch media kept and describe the process for archiving and retrieving off-site media. 39. Is backup storage media kept kept on-site? If so, provide a list and and the location of such m media edia kept and describe the process for archiving and retrieving on-site media; 40. Identify and describe the criteria criteria and methodology u used sed to select the information information to be backed up.

Interrogatories Regarding Document Retention Policy & Collection 41. Identify and attach any and all versions of document document/data /data retention policies policies used by _______________ _____________ __ during the relevant time period of this litigation.

 

42. Identify documents or classes of documents documents that were subject to scheduled destruction. Attach copies of document destruction inventories/logs/schedules inventories/logs/schedules containing documents relevant to this action. Attach a copy of any disaster recovery plan. Also state: the date, if any, any, of the suspension of this policy in toto or any aspect of said policy in response to this litigation; a description by topic, creation date, user or bytes of any and all data that have been deleted or in any way destroyed after the commencement of this litigation. 43. State whether the deletion or or destruction of any data purs pursuant uant to said data retentio retention n policy occurred through automation or by user action.

 

44. Was there a companywide instruction regarding the susp suspension ension of said data retention/destruction retention/destruction policy that occurred after or was related to the commencement of this litigation? If so, identify the individual responsible for enforcing said suspension. 45. Describe all efforts taken taken since the ling of this act action ion to gather and secure docum documents, ents, including but not limited to: electronically generated or stored word processing les, electronic mail, and backup copies of information that may be discoverable or lead to the discovery of admissible

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evidence. 46. Describe all record retention and and destruction policies policies and procedures followed during during the relevant period of time, including, but not limited, to the date the policy was adopted, the types of documents covered in the respective retention period, the frequency of document destruction, whether any record is kept of what documents are destroyed, the manner the policy has been communicated to your employees and the identity of all employees with responsibility of implementing and executing such policies.

Sample Electronic Data Discovery Document Requests 47. All documents which which constitute, refer or relate to writ written ten policies, procedures and guidelines as they relate to computers, computer systems, electronic data, electronic documents and electronic media during the relevant time period of this litigation. 48. All documents which which constitute, refer or relate to any p past ast or corporate policies con concerning cerning employee use of company computers, cell phones, PDAs, and data during the relevant time period of this litigation.

 

49. All documents which which constitute, refer or relate to any p past ast or computer system systemss used by you during the relevant time period of this litigation. 50. All documents which which constitute, refer or relate to any p past ast or backup policies and p procedures rocedures used during the relevant time period of this litigation. 51. All documents which which constitute, refer or relate to any p past ast or records retention and des destruction truction policies and procedures used during the relevant time period of this litigation. 52. All documents which which constitute, refer or relate to any p past ast or electronic commu communications nications systems, systems, including but not limited to: e-mail, voice mail, text messaging and instant messaging, used during the relevant time period of this litigation. 53. All documents which which constitute, refer or relate to any p past ast or backup rotation sch schedules edules used during the relevant time period of this litigation. 54. All documents which which constitute, refer or relate to any p past ast or archival or backup facilit facilities ies used during the relevant time period of this litigation. 55. All documents which which constitute, refer or relate to any el electronic ectronic data retention, preserv preservation ation and destruction schedules during the relevant time period of this litigation. 56. All documents which which constitute, refer or relate to any em employee ployee use policies o off company computers, data, and other technology during the relevant time period of this litigation. 57. All documents which which constitute, refer or relate to any l lee naming convention conventions, s, standards, protocols or policies during the relevant time period of this litigation.

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58. All documents which which constitute, refer or relate to any p password, assword, encryption, and ot other her security protocols used during the relevant time period of this litigation.  

59. All documents which constitute, refer or relate to any diskette, CD, DVD, and other removable media labeling standards used during the relevant time period of this litigation. 60. All documents which which constitute, refer or relate to any e-m e-mail ail storage conventio conventions, ns, including but not limited to, limitations on mailbox sizes/storage locations, and any schedule and logs for storage used during the relevant time period of this litigation. 61. All documents which which constitute, refer or relate to any el electronic ectronic media deploym deployment, ent, allocation, and maintenance procedures for new employees, employees, or departed employees used during the relevant time period of this litigation. 62. All documents which which constitute, refer or relate to any ssoftware oftware and hardware upgrades, incl including uding patches, and the names of the person who conducted the upgrade and the date of the upgrade during the relevant time period of this litigation. 63. All documents which which constitute, refer or relate to any p personal ersonal or home comput computer er usage for work- related activities during the relevant time period of this litigation. 64. All documents which which constitute, refer or relate to any o organization rganization charts fo forr all Information Technology or Information Services departments or divisions from during the relevant time period of this litigation. 65. All documents which which constitute, refer or relate to any b backup ackup tapes containing e-m e-mail ail and other electronic data related to this action from during the relevant time period of this litigation. 66. All documents which which constitute, refer or relate to any ex exact act copies (i.e., bit-by-bit copi copies) es) of all hard drives on the desktop computers, laptop computers, notebook computers, personal digital assistant computers, servers, and other electronic media related to this action during the relevant time period of this litigation. 67. All documents which which constitute, refer or relate to any ex exact act copies of all relevant disk disks, s, CDs, DVDs and other removable media related to this action during the relevant time period of this litigation.

Sample Electronic Data Discovery Request to Inspect 68. Defendant requests that plaintiff plaintiff permit defendant defendant to enter plaintiff’s plaintiff’s premises located at ____________________ _____________ _______ to inspect, test, sample and copy the data, records and les including e- mail, hard drives, computer memory, other storage devices, backup tapes and any other computer systems located on said premises.

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