ESI Depositions

You need a detailed deposition outline checklist when you take the discovery deposition of the adversary's Information Technology (IT) witness who is in charge of their Electronically Stored Information (ESI).

Electronic Records Discovery Deposition Checklist is a simple, easy to follow, means of listing the questions you should ask when you want to know what electronically stored information exists and where it is located in the computer of the adversary.

Comprehensive 26 single spaced page form outline checklist! The cost is less than $2 a page, to give you a real system to prepare quickly and efficiently for one of the toughest types of depositions to take properly!

Electronic Records Discovery Deposition Checklist gives give you a detailed outline checklist of questions within each the 17 major divisions of questions you will ask the adversary's person who knows most about the adversary's ESI (Electronically Stored Information) and IT (electronic storage systems and software) The deponent may be the chief information officer or information technology manager of a large company, or it may simply be the secretary in a two person business). Whoever is the deponent, your adversary counsel will have advised them to "not volunteer" information if not asked. Thus, you need to know the specific questions to ask.

This is a simple to follow checklist for a complex subject. Before the deposition, you'll know what you need to ask the witness --- and you will be organized for asking questions about electronic information storage and discovering what is available.

Why is this a detailed, long, questions checklist? Information Technology (IT) is a term encompassing the electronic storage of information and the systems that store and manipulate all sorts of data, from writing letters and emails, to automatic daily updating of sales and profits. Information Technology refers to both the hardware and software that are used to store, retrieve, and manipulate information. At the lowest level you have the computers or servers with an operating system. Installed on these servers are things like database and web serving software. The servers and computers are connected to each other and to users via a network infrastructure. And the users accessing these servers have their own hardware, operating system, and software tools. All of these hardware pieces are storage devices and many be connected to other electronic storage devices.

In many cases today, taking the deposition of the adverse party's person who knows most about their computer system and its electronically stored information (ESI) involves you in questioning a knowledgeable deponent on a huge number of items on which you need detailed information. You need the detailed information you can discover in an electronic records discovery deposition. Without the information, you cannot make effective ESI demands or bring targeted discovery or sanction motions to the court.

We repeat what we said before: "This is a simple to follow checklist for a complex subject." Yet because of the huge amount of detailed information you need, the LawyerTrialForms™ copyrighted" Checklist: Deposition of IT (Electronically Stored Information) Person" may be the longest deposition checklist outline you have ever seen. (It's also called our "Electronic Records Discovery Deposition Checklist.") You can always strike out or amend questions, but they are all there to give you ideas and to be there when you need them.

Here is the outline table of contents of Checklist: Deposition of IT (Electronically Stored Information) Person

  1. BACKGROUND ON THE DEPONENT AND EMPLOYER
  2. RECORDS AND DOCUMENTS AT THE DEPOSITION
  3. WHO HANDLES, OR HAS ACCESS TO, THE INFORMATION TECHNOLOGY STRUCTURE OF THE COMPANY?
  4. HARDWARE: COMPUTERS, SERVERS, AND STORAGE DEVICES
  5. PERSONAL EQUIPMENT AND WORKSTATION AVAILABILITY
  6. EMAIL
  7. VOICE MAIL
  8. WORD PROCESSING
  9. SOFTWARE PROGRAMS THAT MAY BE INVOLVED
  10. DATABASES OF YOUR SPECIAL INTEREST
  11. SECURITY: ACCESS AND ESI CHANGES
  12. SUBSTANTIVE ESI YOU CAN GATHER TODAY
  13. COMPANY INTERNET AND INTRANET SITES
  14. PROCEDURES ON BACKUP, STORAGE, AND DESTRUCTION
  15. LITIGATION HOLD EVENTS, POLICIES, AND PROCEDURES
  16. YOU DID NOT PRESERVE THAT? THEY DESTROYED THAT?
  17. SUBSTANTIVE INFORMATION DEPONENT KNOWS
  18. HOW YOU WANT TO END THIS DEPOSITION

This deposition outline is not limited to big cases with lots of computers involved. The Electronic Records Discovery Deposition Checklist (also known as the Checklist: Deposition of IT and Electronic Records Person) can be used by you to ease your e-discovery way in just about every litigated case you do. You may not be taking a deposition of the company's person in charge of the computer network, but in every business litigation case, during the deposition of some corporate employee, you probably will want to ask some of these questions. Once you get onto the subject of electronic records of the witness (or of his/her company), you can use the "Deposition of Company Computer Information Officer" checklist to remind you of possible questions you should ask the witness

And of course, Electronic Records Discovery Deposition Checklist also works as a checklist in building your Demand For Production or your Request for Items to Bring to the Deposition.

Everything's guaranteed. No questions. No red tape. The best guarantee in the law form business. If you do not agree this is worth every penny, just ask for your money back in 60 days. You keep our product. You get your money back! You cannot get a better guarantee. You have nothing to lose!


Leonard Bucklin

Dear Fellow Attorney,

LawyerTrialForms™ copyrighted "Electronic Records Discovery Deposition Checklist" is available to give you a real system to prepare quickly and efficiently for one of the toughest types of depositions to take. With this form you will be so well prepared that even seasoned litigators will assume you have done a lot of these ESI electronic discovery depositions.

Before I had a set of comprehensive deposition checklists, for all the standard issues in all types of cases (and believe me, in the last ten years, computers and the electronically stored information has become a standard issue), I would spend hours getting my notes ready for a deposition.

I would spend all that time --- before I had a set of comprehensive depositions checklist --- so I could ask all the right questions in a deposition. But --- after 35 years of litigation, I had developed wonderful checklists that I could whip out and be half way to final depo or trial question preparation even without lifting another finger. I had no trouble being fully prepared on the issues needing discovery, sometimes in a half-hour.

The fact is, most attorneys don't like being fully prepared for a deposition for one simple reason:

They do not want to spend the time.

Most attorneys have no real system to prepare for a deposition. They waste time, and they miss issues and questions they should ask.

But that doesn't have to be you.

I'll say this again: LawyerTrialForms™ copyrighted "Electronic Records Discovery Deposition Checklist" is available to give you a real system to prepare quickly and efficiently.

All The Best,

Leonard Bucklin, Civil Trial Attorney

P.S. Did you know that you'll get instant access to Electronic Records Discovery Deposition Checklist? When you purchase you are directed automatically to a link to click to download the form into your computer in PDF format. Get started just minutes from right now!

P.P.S. The price of the 26 page Electronic Records Discovery Deposition Checklist is just $44. Consider the time involved in trying to build your own deposition outline checklist "from scratch," and you will know you cannot be without this form. Click the "Buy Now" button to get Electronic Records Discovery Deposition Checklist.


100% Satifisfaction Guarentee

Our "100% money back, No Questions Asked, Guarantee."

If you don't totally agree that the book with all its forms is worth every penny, simply tell us within 60 days to refund your money. You keep our book; we refund your money. What could be better!
Read our guarantee here!

PayPal Verified

No Legal Advice. LawyerTrialForms™ articles and legal forms are intended to provide information about the subject matter covered, but are provided with the understanding that the author, editor, and publisher do not render legal or other professional services. If legal advice or other expert assistance is required, seek the service of a competent professional. Attorneys using our publications in dealing with a specific legal matter should exercise their own independent judgment and research original sources of authority and law.

Trademarks and Copyrights 1998 to 2014, Leonard Bucklin.

All intellectual property rights protected and reserved worldwide. Read Copyright, Trademark, Warnings, Disclaimers, Terms of Use, and other Legal Notices in our Legal Notices.

Site design and maintenance provided by Vivid Designs
Hosting provided by Sivad Web