A Discovery Deposition to find an Adversary's Electronically Stored Information (ESI) begins with a Checklist.

This legal deposition form checklist is designed for an attorney taking the deposition of any employee or business officer in regard to the Electronically Stored Information (ESI) and retained copies of the business.

Electronic Records Discovery Deposition Checklist gives  you a detailed outline of each the 17 major divisions of the hundreds of questions you can ask the adversary's chief information officer or information technology manager  .  Although powerful enough for use in cases involving large corporations (e.g., (the information technology (IT) manager in a corporation), it also is designed by our author to guide you in  for ESI depositions of any employee in any size business (e.g.,  a secretary in a two person business).

 "Contents at a Glance"

Checklist: Deposition of IT Person
regarding Electronically Stored Information

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 INFORMATION 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

Comprehensive 26 single spaced page form outline checklist!

This is a simple to follow checklist. 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.

Fact: today, most external and internal correspondence is either e-mail or it is written on a computer, and the sender's copy is kept electronically. In today’s world most documents and data of any kind are electronic. Studies in the United States show that at the beginning of this 21st century over 90% of new correspondence and data was stored electronically, not in file cabinets. Now a few years later, it is approaching the 98% mark, and heading higher.

Beta Test Offering Price no longer available. Some of you may have seen this form earlier on this site for less than its present price.  That was an initial offering to receive the benefits of lawyer testing.  NONETHELESS --- at this site --- , we are able to offer you  a new special price, but only until the end of .  We expect the price of this unique form -  a deposition checklist available only at two locations - to increase during this year.

Electronically Stored Information (ESI), with its metadata, is hard to discovery --- unless you know the questions to ask.  If you don't know the questions, the deponent your adversary attorney has selected for you to depose will know how to "not volunteer" and avoid questions. You need targeted  questions to get the answers of what eData is stored and where is stored, (and what intentionally was deleted). That is why you need a detailed checklist outline.!

This outline form “Electronic Records Discovery Deposition" can be used by you to ease your way in just about every litigated case you do that involves business records. You may not be taking a deposition of the company’s person in charge of the computer network, but 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 his/her company, you will probably want to use the “Electronic Records Discovery Deposition” checklist to remind you of possible questions you should ask the witness

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

What is the Electronic Records Discovery Deposition form?

Electronic Records Discovery Deposition is a checklist.  It is a simple, easy to follow, standard for listing and evaluating the questions you should ask.  Because business computer systems have so many differences from company to company, we cannot give you a checklist of every conceivable thing you will have to ask.  But with 26 pages of outlined questions, you probably will not have to add much to the outline to be out the door and our your way to a successful deposition.

This is a simple to follow checklist. Before the deposition, you'll know what you need to ask the witness--- and you will be organized for electronic discovery!

All The Best,
 
Leonard Bucklin, Civil Trial Attorney

P. S. You have nothing to lose!  Either you will be delighted at the amount of help you got from starting with our checklist, or you get your money back.  That is simple.  No red tape.  No questions.  So you may as well give this a try.  We are sure enough of the value of  Electronic Records Discovery Deposition Checklist that we give you our full 60 day use and 100% money back guarantee.  You have nothing to lose because of the 100% guarantee.

P.P.S. Remember, if you act by the end of , this form, with its 26 single spaced pages is available for the price of only $56.

P.P.P.S Did you know that you'll get instant access to Electronic Records Discovery Deposition Checklist.  As soon as you pay, your browser is automatically directed to a new page with a link to click to download your product immediately. f you have a deposition tomorrow, get started just minutes from right now!


Do you want outstanding results in civil trial litigation?  We give you the benefits of the experience, packaged for immediate use in your law firm, for your next deposition, negotiation, and trial.

Return to the Product Catalog

Copyright 2005 to 03/06/2006 Leonard Bucklin.  All rights reserved except as licensed in writing.
Using this website or making a purchase means you accept
Our copyright and terms of website use and purchase.  
  Additional sites information