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
- BACKGROUND ON THE DEPONENT AND EMPLOYER
- RECORDS AND DOCUMENTS AT THE DEPOSITION
- WHO HANDLES, OR HAS ACCESS TO, THE INFORMATION TECHNOLOGY STRUCTURE OF THE COMPANY?
- HARDWARE: COMPUTERS, SERVERS, AND STORAGE DEVICES
- PERSONAL EQUIPMENT AND WORKSTATION AVAILABILITY
- VOICE MAIL
- WORD PROCESSING
- SOFTWARE PROGRAMS THAT MAY BE INVOLVED
- DATABASES OF YOUR SPECIAL INTEREST
- SECURITY: ACCESS AND ESI CHANGES
- SUBSTANTIVE ESI YOU CAN GATHER TODAY
- COMPANY INTERNET AND INTRANET SITES
- PROCEDURES ON BACKUP, STORAGE, AND DESTRUCTION
- LITIGATION HOLD EVENTS, POLICIES, AND PROCEDURES
- YOU DID NOT PRESERVE THAT? THEY DESTROYED THAT?
- SUBSTANTIVE INFORMATION DEPONENT KNOWS
- 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.
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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
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