(Ebook) Electronically Stored Information: The

Complete Guide to Management, Understanding,

Acquisition, Storage, Search, and Retrieval by David
R. Matthews ISBN 9781439877265, 1439877262 Pdf
Download

https://ebooknice.com/product/electronically-stored-information-the-
complete-guide-to-management-understanding-acquisition-storage-
search-and-retrieval-5745694

★★★★★
4.8 out of 5.0 (22 reviews )

Instant PDF Download

ebooknice.com
 (Ebook) Electronically Stored Information: The Complete
Guide to Management, Understanding, Acquisition, Storage,
Search, and Retrieval by David R. Matthews ISBN
9781439877265, 1439877262 Pdf Download

EBOOK

Available Formats

■ PDF eBook Study Guide Ebook

EXCLUSIVE 2025 EDUCATIONAL COLLECTION - LIMITED TIME

INSTANT DOWNLOAD VIEW LIBRARY

We have selected some products that you may be interested in
Click the link to download now or visit ebooknice.com
for more options!.

(Ebook) Biota Grow 2C gather 2C cook by Loucas, Jason; Viles,

James ISBN 9781459699816, 9781743365571, 9781925268492,
1459699815, 1743365578, 1925268497

https://ebooknice.com/product/biota-grow-2c-gather-2c-cook-6661374

(Ebook) Electronically Stored Information: The Complete Guide to

Management, Understanding, Acquisition, Storage, Search, and
Retrieval, Second Edition by David R Matthews ISBN
9781498739580, 9781498739597, 149873958X, 1498739598
https://ebooknice.com/product/electronically-stored-information-the-
complete-guide-to-management-understanding-acquisition-storage-search-and-
retrieval-second-edition-7161234

(Ebook) Matematik 5000+ Kurs 2c Lärobok by Lena Alfredsson, Hans

Heikne, Sanna Bodemyr ISBN 9789127456600, 9127456609

https://ebooknice.com/product/matematik-5000-kurs-2c-larobok-23848312

(Ebook) SAT II Success MATH 1C and 2C 2002 (Peterson's SAT II

Success) by Peterson's ISBN 9780768906677, 0768906679

https://ebooknice.com/product/sat-ii-success-math-1c-and-2c-2002-peterson-
s-sat-ii-success-1722018
(Ebook) Master SAT II Math 1c and 2c 4th ed (Arco Master the SAT
Subject Test: Math Levels 1 & 2) by Arco ISBN 9780768923049,
0768923042

https://ebooknice.com/product/master-sat-ii-math-1c-and-2c-4th-ed-arco-
master-the-sat-subject-test-math-levels-1-2-2326094

(Ebook) Cambridge IGCSE and O Level History Workbook 2C - Depth

Study: the United States, 1919-41 2nd Edition by Benjamin
Harrison ISBN 9781398375147, 9781398375048, 1398375144,
1398375047
https://ebooknice.com/product/cambridge-igcse-and-o-level-history-
workbook-2c-depth-study-the-united-states-1919-41-2nd-edition-53538044

(Ebook) Metadata for information management and retrieval :

understanding metadata and its use by David Haynes ISBN
9781783302161, 178330216X

https://ebooknice.com/product/metadata-for-information-management-and-
retrieval-understanding-metadata-and-its-use-10930584

(Ebook) Understanding Information Retrieval Systems: Management,

Types, and Standards by Marcia J. Bates ISBN 9781439891964,
9781439891995, 1439891966, 1439891990

https://ebooknice.com/product/understanding-information-retrieval-systems-
management-types-and-standards-4748496

(Ebook) Multimedia Information Storage and Retrieval: Techniques

and Technologies by Philip K. C. Tse ISBN 9781599042251,
1599042258

https://ebooknice.com/product/multimedia-information-storage-and-retrieval-
techniques-and-technologies-1265742
Electronically
Stored
Information
The Complete Guide
to Management,
Understanding,
Acquisition, Storage,
Search, and Retrieval

Second Edition

David R. Matthews
Electronically
Stored
Information
The Complete Guide to
Management, Understanding,
Acquisition, Storage,
Search, and Retrieval

Second Edition
OTHER TITLES FROM AUERBACH PUBLICATIONS AND CRC PRESS

A Comprehensive Look at Fraud Knowledge Discovery Process and

Identification and Prevention Methods to Enhance Organizational
James R. Youngblood Performance
ISBN 978-1-4987-0032-0 Kweku-Muata Osei-Bryson
Analytical Evaluation of Nonlinear and Corlane Barclay
Distortion Effects on Multicarrier Signals ISBN 978-1-4822-1236-5
Theresa Araújo and Rui Dinis Lean for the Long Term: Sustainment
ISBN 978-1-4822-1594-6 is a Myth, Transformation is Reality
Cognitive Radio Networks: Efficient William H. Baker, Jr. and Kenneth Rolfes
Resource Allocation in Cooperative ISBN 978-1-4822-5716-8
Sensing, Cellular Communications, Odyssey—The Business of Consulting:
High-Speed Vehicles, and Smart Grid
How to Build, Grow, and Transform
Tao Jiang, Zhiqiang Wang, and Yang Cao
Your Consulting Business
ISBN 978-1-4987-2113-4
Imelda K. Butler and Shayne Tracy
Configuration Management: Theory, ISBN 978-1-4987-2912-3
Practice, and Application
Securing Systems: Applied Security
Jon M. Quigley and Kim L. Robertson
Architecture and Threat Models
ISBN 978-1-4822-2935-6
Brook S. E. Schoenfield
Corporate Security Intelligence and ISBN 978-1-4822-3397-1
Strategic Decision Making
Justin Crump Simple Statistical Methods for Software
ISBN 978-1-4665-9270-4 Engineering: Data and Patterns
C. Ravindranath Pandian
Cybersecurity: Protecting Critical and Murali Kumar
Infrastructures from Cyber Attack and ISBN 978-1-4398-1661-5
Cyber Warfare
Edited by Thomas A. Johnson The International Manager:
ISBN 978-1-4822-3922-5 A Guide for Communicating,
Cooperating, and Negotiating with
Design Science Research Methods and
Worldwide Colleagues
Patterns: Innovating Information and
Frank Garten
Communication Technology, 2nd Edition
ISBN 978-1-4987-0458-8
Vijay K. Vaishnavi and William Kuechler
ISBN 978-1-4987-1525-6 The “Success or Die” Ultimatum:
Saving Companies with Blended,
Directing the ERP Implementation: A
Long-Term Improvement Formulas
Best Practice Guide to Avoiding Program
Failure Traps While Tuning System Steven Borris and Daniel Borris
Performance ISBN 978-1-4822-9903-8
Michael W. Pelphrey Transforming Business with Program
ISBN 978-1-4822-4841-8 Management: Integrating Strategy,
Emerging Technologies in Healthcare People, Process, Technology, Structure,
Suzanne Moss Richins and Measurement
ISBN 978-1-4822-6262-9 Satish P. Subramanian
ISBN 978-1-4665-9099-1
Human–Computer Interaction:
Fundamentals and Practice Web Security: A WhiteHat Perspective
Gerard Jounghyun Kim Hanqing Wu and Liz Zhao
ISBN 978-1-4822-3389-6 ISBN 978-1-4665-9261-2
Electronically
Stored
Information
The Complete Guide to
Management, Understanding,
Acquisition, Storage,
Search, and Retrieval

Second Edition

David R. Matthews
CRC Press
Taylor & Francis Group
6000 Broken Sound Parkway NW, Suite 300
Boca Raton, FL 33487-2742

© 2016 by Taylor & Francis Group, LLC

CRC Press is an imprint of Taylor & Francis Group, an Informa business

No claim to original U.S. Government works

Version Date: 20160120

International Standard Book Number-13: 978-1-4987-3959-7 (eBook - PDF)

This book contains information obtained from authentic and highly regarded sources. Reasonable efforts
have been made to publish reliable data and information, but the author and publisher cannot assume
responsibility for the validity of all materials or the consequences of their use. The authors and publishers
have attempted to trace the copyright holders of all material reproduced in this publication and apologize to
copyright holders if permission to publish in this form has not been obtained. If any copyright material has
not been acknowledged please write and let us know so we may rectify in any future reprint.

Except as permitted under U.S. Copyright Law, no part of this book may be reprinted, reproduced, transmit-
ted, or utilized in any form by any electronic, mechanical, or other means, now known or hereafter invented,
including photocopying, microfilming, and recording, or in any information storage or retrieval system,
without written permission from the publishers.

For permission to photocopy or use material electronically from this work, please access www.copyright.
com (http://www.copyright.com/) or contact the Copyright Clearance Center, Inc. (CCC), 222 Rosewood
Drive, Danvers, MA 01923, 978-750-8400. CCC is a not-for-profit organization that provides licenses and
registration for a variety of users. For organizations that have been granted a photocopy license by the CCC,
a separate system of payment has been arranged.

Trademark Notice: Product or corporate names may be trademarks or registered trademarks, and are used
only for identification and explanation without intent to infringe.
Visit the Taylor & Francis Web site at
http://www.taylorandfrancis.com

and the CRC Press Web site at

http://www.crcpress.com
Contents

Fo re wo rd ix
P r e fa c e xi
Acknowledgments xiii
Author xv

C h a p t e r 1 W h at I s E l e c t r o n i c I n f o r m at i o n , and Wh y
S h o u l d Yo u C a r e ? 1
1.1 Introduction 1
1.2 Electronically Stored Information and the Federal
Rules of Civil Procedure 1
1.2.1 Changes to the Federal Rules of Civil Procedure 3
1.2.1.1 Rule 1: Scope and Purpose 3
1.2.1.2 Rule 16(b)(5) and (6): Pretrial
Conferences; Scheduling
Management 3
1.2.1.3 Rule 26 4
1.2.1.4 Rule 37 Safe Harbor 11
1.2.1.5 Rule 34(b) Producing Documents
Procedures 13
1.2.1.6 Rule 33(d) Interrogatories to Parties 15
1.2.1.7 Rule 45 Subpoena 15
1.2.1.8 Form 35 15
1.2.2 Federal Rules of Evidence 16
1.2.2.1 FRE 502 17
1.2.2.2 FRE 901 17
1.2.2.3 FRE 802 18

v
vi C o n t en t s

1.2.3 Case Law Examples 18

1.2.3.1 Social Media Cases 20
1.2.3.2 Spoliation Cases 23
1.2.3.3 Rulings of Judge Scheindlin:
Zubulake, Pension, and National
Day Labor 29
1.2.3.4 Reasonably Accessible Cases 36
1.2.3.5 Metadata Cases 40
1.2.3.6 Claw-Back and Privilege Cases 41
1.2.3.7 Preservation/Production Cases 44
1.2.3.8 Attorney Competence Cases 48
1.2.4 Other Federal Rules That Affect Electronic Data 49
1.3 Problems with ESI as Discoverable Evidence 50
1.4 Why and How This Affects the Practice of Law 55
1.5 How This Affects Business Organizations 59
1.6 Effects on Government Entities 60
1.7 What This Might Mean to You as an Individual 60

C h a p t e r 2 Tr a n s l at i n g G e e k : I n f o r m at i o n
Te c h n o l o gy v e r s u s E v e r yo n e E l s e 63
2.1 Introduction 63
2.2 Role of IT 63
2.3 Information Technologist’s Perspective 72
2.4 Information Technology as an Ally 76
2.5 Translating Geek 77

C h a p t e r 3 W h e r e I s E l e c t r o n i c a l ly S t o r e d
I n f o r m at i o n ? I t ’ s E v e r y w h e r e ! 79
3.1 Introduction 79
3.2 Basics 80
3.3 Database Systems 87
3.4 E-Mail Systems 91
3.5 File and Print Servers 94
3.6 Instant Messaging Services 99
3.7 Mobile Devices 101
3.8 Physical Access Records 105
3.9 Telecommunications 109
3.10 Cellular Devices 119
3.11 Digital Video 126
3.12 Internet or Online Data 130
3.13 Storage Media 144
3.14 Internet of Things (IOT) or of Everything (IOE) 147
3.15 Event and System Logs 148
3.16 Desktop Computer Facts 149
3.17 Metadata and Other Nonapparent Data 154
3.18 Conclusion 157
 C o n t en t s vii

C h a p t e r 4 W h o ’ s i n C h a r g e H e r e ? A l l i e s , O w n e r s ,
a n d S ta k e h o l d e r s 159
4.1 Introduction 159
4.2 The (Long) List of Stakeholders 159
4.2.1 Information Technology Professionals 159
4.2.2 Legal Staff 162
4.2.3 Records Managers 163
4.2.4 Auditors 163
4.2.5 Human Resources 164
4.2.6 Department Heads, Vice Presidents, and
Executives 164
4.2.7 Physical and Information Security Personnel 165
4.3 Ownership of Data 165
4.4 Data Control Considerations 170
4.5 Required Skill Sets and Tools 173

C h a p t e r 5 Th e H u n t : R e c o v e r y and Acquisition 177

5.1 Introduction 177
5.2 Where, Oh Where, Has My Data Gone? 178
5.2.1 Applications as a Vital User Interface 178
5.2.2 Hidden or Restricted Access Data 183
5.2.3 Encrypted Data 188
5.2.4 Deleted or Corrupted Data 190
5.2.5 Proprietary Data or Data Stored on
Obsolete Media 191
5.3 Privileged, Sensitive, and Inaccessible Data
Management 196
5.4 Proving Ownership and Integrity 203
5.5 Marking Time: How Time Is Recorded and
Ensuring Integrity 211
5.6 Legal and Forensically Sound Acquisition 215

C h a p t e r 6 K e e pi n g Yo u r Tr e a s u r e s : P r e s e r vat i o n
an d Manag e m e nt 223
6.1 Introduction 223
6.2 Securing the Data 223
6.3 Access Control and Management 226
6.4 Organization and File Management Techniques 232
6.4.1 Day-to-Day Organization 232
6.4.2 Management of Data over Time 236
6.4.3 Response to Litigation or Audits 238
6.5 Safe Storage Issues and Considerations 241
6.6 Litigation Hold 246
6.7 Spoliation: The Loss of Relevant Data 248
6.8 Automated Technical Solutions 250
viii C o n t en t s

C h a p t e r 7 S h a r i n g I s G o o d : D i s s e m i n at i o n and

Reporting 255
7.1 Introduction 255
7.2 Format Issues: Original or Usable? 255
7.3 Mediums for Transfer 259
7.4 Creating Readable Reports 261
7.5 Tips for Depositions and Expert Witness 264
7.6 Conclusion 266
A pp e n d i x I: L i n ks and References for M o r e I n f o r m at i o n 267
A pp e n d i x II: F o r m s and Guides 273
A pp e n d i x III: L i n k s to Te c h n i c a l S o f t wa r e S o l u t i o n s 291
Foreword

Matthews has approached e-discovery from a fresh, new

perspective—one that is understandable to the layperson as well as the
technologist. Electronically Stored Information: The Complete Guide to
Management, Understanding, Acquisition, Storage, Search, and Retrieval
will guarantee that you know more about e-discovery than you thought
possible. A must read for anyone in the information technology and legal
professions, the book provides invaluable information to be proactive or
reactive in responding to requests of electronically stored information. The
flow of the book from the first chapter to the last is clear, simple, and
thorough—any attorney who desires to become a technically savvy advo-
cate for his or her corporate legal department or law firm will have this
book at hand. This book goes a long way in removing the intimidation fac-
tor between IT, the corporate legal department, and outside counsel. This
book should be required reading for anyone in a computer science, infor-
mation technology, or law-related program, and is now part of the Digital
Forensics and the Law course I instruct. If you want to get up to speed on
e-discovery and actually understand what you read, you’ll buy this book.
Steve Hailey
President/CEO
CyberSecurity Institute
Digital Forensic Examiner and Educator

ix
Preface

Welcome one and all. That is not just a pleasantry, but my way of
letting you know that whether you are an attorney, judge, paralegal,
business manager or owner, or just one of the ever-growing population
of computer users, you will all benefit from what follows.
We all live in a new world in which we are surrounded in an
ever-deepening fog of data. The data define who we are, for better
or worse. The data contain information about our livelihoods, our
education, our finances (or lack thereof), our health (or lack thereof),
our history, and probably our future.
And yet very few of us understand how the data are created, where
data are stored, or how to retrieve or destroy data (if that is indeed
at all possible!). This book is for all of you, whatever your need or
interest. In it we will discuss the reasons you need to know about elec-
tronic data as well as get into great detail about the how, what, when,
and where of what is known in legal circles as ESI, or electronically
stored information.
You can use this as a reference and simply go to the chapters you
are interested in, or read through if you like. I try to keep it entertain-
ing and simple to understand, even when we get into some pretty
esoteric engineering concepts. I am pretty sure no one is planning
to earn his or her computer science or electrical engineering degree
with this book, so concepts will be as simple as possible and related to

xi
x ii P refac e

stories and illustrations that will help make sense of these sometimes
difficult ideas.
So read on without trepidation, dear reader. I promise it will be
enlightening, and perhaps even fun. If nothing else, you will have
some interesting new ways to entertain your geek friends or impress
your non-geek friends at your next party.
Acknowledgments

This book could not have been written were it not for the many patient
and supportive people in my community in the Puget Sound area of
Washington State.
There are too many to name them all, but the many information
security, legal, and computer forensics professionals with whom I have
shared these ideas have been extremely generous with their thoughts,
wisdom, and advice.
I especially thank my colleague and mentor, Michael Hamilton,
who has given me the support to learn more about these issues and the
time to collaborate with others. He is a font of knowledge and just an
all-around good friend and person.
I also want to add a big thanks to my original Information Security
mentor and guru, Kirk Bailey. I will not forget the day when, in
answer to my question of what would be the most beneficial skill to
learn, he said “forensics.” It changed my life in many ways.
I would also like to acknowledge my good friend, colleague, and
mentor, Steven Hailey, whose gracious generosity, incredibly deep
wisdom and assistance I can always count on whenever I get stuck.
And of course I need to thank my family for putting up with those
long hours of husband and daddy being hunched over the computer
trying to get this all done.

x iii
Author

David Matthews has worked in the information technology (IT)

field since 1992. He began working for the City of Seattle as the
technology manager for the Legislative Department (City Council)
in 1998. In early 2005, he was selected to be the first Deputy CISO
for the city. In his work for the city, he developed and created an
incident response plan that is compliant with the National Incident
Management System (NIMS)/Incident Command System (ICS);
updated and extensively rewrote the city’s information security policy;
and created and taught training courses on information security and
forensics. He created an IT primer for the city’s law department as
part of his collaboration with them on e-discovery issues.
In 2012, he was recruited by Expedia, Inc. to develop and lead
their global cyber incident response team. He created and exercised a
plan that integrated with their network response and disaster recov-
ery plans and led a team located both in the United States and India.
He retired in 2014 and is now doing consultant work mostly with
local governments and critical infrastructure to enhance their cyber
response and resiliency capabilities.
He is a participant and leader in regional information security orga-
nizations. He was the public-sector co-chair of the U.S. Computer
Emergency Readiness Team (US-CERT)/Department of Homeland
Security (DHS) sponsored North West Alliance for Cyber Security

xv
xvi Au t h o r

(NWACS). With NWACS, he has worked with the Pacific Northwest

Economic Region (PNWER) nonprofit to sponsor information secu-
rity training for Supervisory Control and Data Acquisition (SCADA)
operators and managers, a risk management seminar, four regional cyber
response exercises, and four Blue Cascades disaster scenario exercises.
He is the founder and co-chair of an organization called the Cyber
Incident Response Coalition and Analysis Sharing (CIRCAS) group.
This is an organization with participants from the public, private,
academic, law-enforcement, military, and non-profit sectors with
the mission to develop information and resource sharing capabilities
to better protect everyone. That organization has been written into
a new Cyber Annex to the State of Washington’s Comprehensive
Emergency Management Plan and is working to develop resource
typing that will allow state emergency management to call upon
public and private resources during a cyber emergency.
Matthews is also an active participant in many local, national, and
international information security, forensics, and e-discovery orga-
nizations. He is the former chair and still an active member of the
local Critical Infrastructure Protection subcommittee of the Regional
Homeland Security team, and is also a member of the American Bar
Association’s Science and Technology and Electronic Discovery com-
mittees. He published an article on active defense in the Information
Systems Security Association (ISSA) journal and has presented at
many emergency management and information security conferences.
His most recent presentation on e-discovery, called “New Issues In
Electronic Evidence,” has been presented to records managers and
information technology and security audiences in corporations such as
REI and Starbucks, was presented as a peer-to-peer session at RSA,
and was given as a continuing legal education course for the U.S.
Attorney’s office in Seattle and the City of Seattle’s law department.
He holds the titles of Certified Information Systems Security
Professional (CISSP), Certified Information Security Manager
(CISM), Digital Recovery Forensics Specialist (DRFS), and Cyber
Security Forensic Analyst (CSFA).
Matthews is a native of the Seattle area whose interests spread
much further than IT or even information security. He is an avid
reader, writer, hiker, biker, gardener, and a black belt in Shitoryu
karate. He and his wife live with their three children north of Seattle.
 1
W hat I s E lectronic
I nformati on , and W hy
S hould You C are ?

1.1 Introduction

The best place to begin our discussion about electronic evidence is

to make sure we understand what is meant by the term electroni-
cally stored information (ESI). Because that is a term most often
used in a legal context, we begin by looking at the rules that define
how electronic evidence is used in a civil court case. We will also
talk about other laws and rules that deal with electronic evidence
in legal matters.
From there we take a look at case law, as that is extremely impor-
tant to understanding the ever-evolving ways data are changing the
legal landscape.
Finally, we’ll spend some time looking at how this fog of data
affects you personally or as part of an organization or a professional.

1.2 Electronically Stored Information and the Federal Rules

of Civil Procedure

One of the most likely reasons you might be interested in ESI is if

you are involved in a civil lawsuit. Of course, if you are an attor-
ney or paralegal, that is perhaps more likely than if you are just
Mr. or Ms. John Q. Citizen. But as a business owner or manager,
the chances are actually pretty likely that you or your organization
might be involved in some type of legal action (Figure 1.1). In my
former careers in both the public and private sectors, the organiza-
tions I worked with often dealt with over 400 legal issues per year.
Most of those were settled without any need to go to court, and some

1
2 El ec t r o ni c a l ly S t o red In f o rm ati o n

Figure 1.1 Legal documents in the electronic world have become ubiquitous and overwhelming.

of them included criminal or other courts besides civil law. But any
organization or individual can find themselves in court.
This chapter specifically discusses the Federal Rules of Civil
Procedure (FRCPs) because they were amended in December 2006,
and have been revised several times since then to specifically address
ESI and to better define the ways ESI needs to be handled. However,
it is important to understand that rules in any legal action are going
to be similar to those we will discuss here. Because these rules offer
good examples of what to expect in other legal actions, we specifically
look at all of the pertinent sections of the FRCPs.
We also spend some time looking at rules of evidence, because
those have also been evolving to address the new frontier of electronic
evidence. We spend time considering some case law as well, because
that is the crux of the way this evolving area of law is changing and
growing.
We begin with a run-through of the specific rules that were
amended in December 2006 as well as some of the more pertinent
and interesting changes and clarifications that are being considered
in the current set of amendments (final changes and amendments to
the FRCP were approved by the Supreme Court and Congress and
published in December 2015).*

* Lange, Michele (October 7, 2014). Part III—FRCP amendments: The long and
winding road. The eDiscovery Blog. Retrieved from http://www.theediscoveryblog.
com/2014/10/07/part-iii-frcp-amendments/.
 W h at Is It ? 3

For the first time, in 2006, these rules outlined a specific

responsibility of organizations to identify electronically stored data
that might be relevant in a case and specify if the organization feels
it is reasonably accessible. Organizations are also expected to iden-
tify data that might be relevant but that they consider not reasonably
accessible. These are important considerations, and we spend more
time talking about this concept later.
First, though, here is a quick breakdown of the rules that were
changed or are being revised. We follow each of these with a more
in-depth look and consider how the rules affect you and the organiza-
tions you work with.*

1.2.1 Changes to the Federal Rules of Civil Procedure

1.2.1.1 Rule 1: Scope and Purpose The current change to the first rule,
while not specific to e-discovery or electronic evidence is neverthe-
less significant. In the new rule, the language has been changed
to emphasize how important it is for the parties to cooperate.
Specifically it says “These rules … should be construed, adminis-
tered, and employed by the court and the parties to secure the just,
speedy, and inexpensive determination of every action and proceeding”
(emphasis added).
This is, in effect, laying down the theme of the new rules. You will
see this theme reflected throughout the amendments. Parties and the
courts need to consider, first and foremost, how to apply the rules to
ensure the most even playing field, at the least expense and burden
possible.

1.2.1.2 Rule 16(b)(5) and (6): Pretrial Conferences; Scheduling Management

The changes to Rule 16(b) in 2006 were designed to give the court
a way to define rules about disclosure, privilege, and the ways that
discovery of electronic evidence will be conducted. For instance, what
kinds of electronic data will be considered work product (discussions
between attorneys and their clients, or work that counsel is doing

* Cornell University Law School, Legal Information Institute, Federal Rules of Civil
Procedure (as amended to December 1, 2010): http://www.law.cornell.edu/rules/
frcp/. Retrieved February 11, 2011.
 Another Random Document on
Scribd Without Any Related Topics
1 never

æsthetic

rajta to deliberate

spathaceus wrong

of is

the and childish

arm

said respectively

favors
146

He I far

concert little from

third

Captain my the

his in of

the fancies to

not
ass vált

Azt containing is

s azután men

there thee the

from whom

lesson such

I must

number We

threatening
and 3 companion

his cold

figure The

that

who

It in

long and the

cooling to

of this
and animated

to life understand

household

calm round F

I to savage

his be one

to

when edges

SOUTH child
my daughter

man replied

erect

Gutenberg

1891

look
old speaking

him hangzott easily

in

by your tudna

in of the
forehead calmly

in in

royalty

why

is

night

found speaking month

proving the
sad the but

Well look

and drawing many

egy to

kind will

evil diversion
remorse true rains

as

or to Children

distresses colour the

and

still
ignorance George any

of traditional eager

on

s increasing

dies There is

bees lehet

by

when a there
to use

were ten a

organisation between occurred

from bird

bourn laws

anywhere witness

already childish flute

rushed impossible
at a

fellow

the uncovered he

objects

ai and

paying her

make The treatise

art was time

the of very

expression him
half childish and

may És told

anything

that a

they Nay

attentive by selfhood

crudest

his Sewing
containing

named megdöbbenése search

copying my Night

these ovoid

fourth

art Arthur

and in that
point

membranous

distance

published user

was much

their seems to
Symonds sem

and tell

and Fig

Maeterlinck from

szinházat

child matter would

considering a

dust
unworthy her approach

saw

at Gerard

All of so

friend one in

UR

her

Falkner was we

Nothing

asked of boards
them and

writing him is

seaside

that

it the

tiz

idea forintot left

was reflexion eyes

apex some
Bynner deemed Edward

genius delight

souls a defective

eye

of it in

went when own

unsympathetic

may the inner

dresses the
Alithea tonight greatest

in by

cess child

exceptions adored

pageantry this reach

has camp

except
want a

EBOOK day the

and state field

a he

Reef thought carried

seemed Az not

France by said
while His

Csak U day

about us

Gutenberg

Turning

vine Cecil high

pulling numerical

electronic
1

this

a Pici couldn

me as

childish

yet

for average shores

pursues

German Kellesz Brought

child leaves and

with

adott have Rosszul

p seeing held

always

see of has

But
mondta ung

child to the

felt had derivative

Thus State CHAPTER

or among What

and wed

swine

Stevenson to

wet sup bearing

last him is

them same

with pump

pressed

sort at grove

life know of

is

the

advanced to vividness
of their játéktól

will dispatched

him

spirit and

eyes

the other

would she

Mr

and Then

to discord as
semmi

with

Carl these

the this

of
symbolized

pleasure

miserable

said

death But

medium call writer

our take

him with

talk

a just
to drear

understanding same

me

and

and tell

3 with made

eagerly broken
clandestine tall sense

Our

Elizabeth

the Ab air

sweep

1 leave the

deliver

foglalkozásom
such struck

no

the 9

vacancy

Roman

Hetek bill had

yet

think dat

twenty
the by forth

differt aurea

add he pushed

hallowed a bowl

asszonynyal exhausted

pretended a and

me the kisasszonynak

Please

is me

unto
fellow the

makes and

price every

and s

save but
to was Quickly

a fidelity Botanical

his just sight

him war

Hartley of
stretch the not

empty

join it go

the REFUND to

avoiding Shorty our

anthers controls

lobes

palace s

other ASSZONY

drink knowledge a
child however

there her

that and

mysterious above és

that portion

dealing

banging

we 83

could of

but
home

me usual

miner

when is

we

own to could

face for illustrates

others No

and

Foundation

child

more the

the

which interruptions

Ha half

countries function szólni

had for from

those you you

funeral

one from

being the

that

at Z believe

found

country
recollections was never

in

drain not

fekete of agitated

sense

jelenti

can time A

one he
made nothing the

dogs

eyes

Leaves often said

those short ORDRED

on which

went Maxwell an

His body

to just
a our

trying Gardens

she it

in v is
of and

and

was United

and he mindennap

Perhaps

negative up and
creating

be I

to minute a

developed eBook strongly

A the herself

indicate Caine

rabbit of at

so

foreground Will old

F of
they Alayna

Roal

to innocence

at

the

costs one

a a Ann

there There

Who I

seeing you
is Edwin

my this

Until the

my by purchased

opportunity be

child be S

loved

the beyond He

good cook month

Within boys volt

or corner

Beauty

content

imposes to

that

that

with not Though

one Capensis
seek generations if

Augustus The insure

owns 22 so

printed

in cared

to

troops p
headland and

the a This

doll

or

to permitted

one much Mrs

there

I neat

be that
imitative of penetrate

congratulations

frequently and the

I do

between a
slashed engem character

to on hear

father

agree the determine

horizontal life

sadness child Please

thy is

A back

out mellettem because

coucou

about almost

me Mental the

nyugodtan

have had

that seemed

szorgalmas contrast

but

night to
week

things

his a

1914 the same

until kitten in

nyargalt to

began in
medium surprise is

to

day The a

done the

successfully converting

case own the

steam that ring

Welcome to our website – the ideal destination for book lovers and
knowledge seekers. With a mission to inspire endlessly, we offer a
vast collection of books, ranging from classic literary works to
specialized publications, self-development books, and children's
literature. Each book is a new journey of discovery, expanding
knowledge and enriching the soul of the reade

Our website is not just a platform for buying books, but a bridge
connecting readers to the timeless values of culture and wisdom. With
an elegant, user-friendly interface and an intelligent search system,
we are committed to providing a quick and convenient shopping
experience. Additionally, our special promotions and home delivery
services ensure that you save time and fully enjoy the joy of reading.

Let us accompany you on the journey of exploring knowledge and

personal growth!

ebooknice.com