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eDiscoveryDaily

eDiscovery Case Law: Defendant Can’t Be Plaintiff’s Friend on Facebook

In Piccolo v. Paterson, Bucks County, Pa., Common Pleas Court Judge Albert J. Cepparulo denied the motion from the defendant requesting access to the photos of plaintiff Sara Piccolo posted in her Facebook account.

Piccolo filed an action against the defendants after being injured in a one-car accident while a passenger in a car driven by defendant Lindsay Paterson. According to the defense motion, filed by attorneys at Moore & Riemenschneider, Piccolo testified she had a Facebook account and was asked at deposition if the defense counsel could send a “neutral friend request” to Piccolo so that he could review the Facebook postings Piccolo testified she made every day.  Piccolo’s attorney, Benjamin G. Lipman , ultimately denied the request, responding that the “‘materiality and importance of the evidence … is outweighed by the annoyance, embarrassment, oppression and burden to which it exposes'” the plaintiff.

The defense argued that access to Piccolo’s Facebook page would provide necessary and relevant information related to the claims by Piccolo and cited a case, McMillen v. Hummingbird Speedway, Inc. (previously summarized by eDiscoveryDaily here), in which the court ordered the plaintiff to provide his username and password to the defendant’s attorney. The plaintiff’s attorney argued that the defense had only asked for the pictures Piccolo posted on Facebook and that they had already been provided with “as complete a photographic record of the pre-accident and post-accident condition” of Piccolo.

As a result of the accident in May 2007, Piccolo suffered lacerations to her lip and chin when hit in the face with an airbag. She had 95 stitches to her face and then surgery to repair her scarring six months later. With permanent scars on her face, Piccolo allowed the insurer in 2008 to take photographs of her face and gave the defense 20 photos of her face from the week following the accident and five photos from the months just before the accident.

In Piccolo’s response to the defense motion, Lipman argued that defense counsel had only asked at Piccolo’s deposition about the pictures she posted on Facebook, not any textual postings. He said that the defendant had already been provided “as complete a photographic record of the pre-accident and post-accident condition” of Piccolo as she “could reasonably have a right to expect in this case.”

Judge Cepparulo agreed, ruling with the plaintiff and denying the defense access to Piccolo’s Facebook page in a one-paragraph motion.

So, what do you think?  Did the judge make the correct call or should he have issued a ruling consistent with McMillen?  Please share any comments you might have or if you’d like to know more about a particular topic.

eDiscovery Trends: Forecast for More Clouds
 

No, eDiscoveryDaily has not begun providing weather forecasts on our site.  Or stock forecasts.

But, imagine if you could invest in an industry that could nearly sextuple in nine years? (i.e., multiply six-fold).

Well, the cloud computing, or Software-as-a-Service (SaaS), industry may be just the industry for you.  According to a Forrester report from last month, the global cloud computing market will grow from 40.7 billion dollars in 2011 to more than 241 billion dollars by 2020.  That’s a 200 billion dollar increase in nine years.  That’s enough to put anybody “on cloud nine”!

The report titled Sizing The Cloud by Stefan Ried (Principal Analyst, Forrester) and Holger Kisker (Sr. Analyst, Forrester), outlines the different market dynamics for three core layers of cloud computing, as follows:

  • Public Cloud: From 25.5 billion dollars to 159.3 billion dollars by 2020;
  • Virtual Private Cloud: From 7.5 billion dollars to 66.4 billion dollars by 2020;
  • Private Cloud: From 7.8 billion dollars to 159.3 billion dollars by 2020.

Public cloud providers include everything from Facebook and Twitter to Amazon.com and Salesforce.com.  As the name implies, a private cloud is where companies implement their own cloud environment to support its own needs.  A virtual private cloud is simply a private cloud located within a public cloud.

Forrester is not the only analyst firm that expects big things for cloud computing.  The Gartner Group projected that the cloud computing industry will have revenue of 148.8 billion dollars by 2014, even higher than Forrester’s forecast of 118.7 billion dollars for the same year.  Clearly, the benefits of the cloud are causing many organizations to consider it as a viable option for storing and managing critical data.

What does that mean from an eDiscovery perspective?  That means a forecast for more clouds.  If your organization doesn’t have a plan in place for managing, identifying, preserving and collecting data from its cloud solutions, things could get stormy!

So, what do you think?  Is your organization storing more data in the cloud?  Does your organization have an effective plan in place for getting to the data when litigation strikes?  Please share any comments you might have or if you’d like to know more about a particular topic.

Working Successfully with eDiscovery and Litigation Support Service Providers: Components of a Preferred Vendor Program
 

Yesterday, we talked about a couple of different ways in which law firms work with litigation support and eDiscovery vendors.  And, we talked about the advantages to a centralized approach and establishing a preferred vendor program.  What, exactly, is a preferred vendor program?  To most people, it’s having a list of pre-approved vendors that that can be called on as the need arises.  That is certainly the core of a preferred vendor program.  But, a good program goes a bit further.  A good program has three basic components:

  1. It starts with a preferred vendor list.  The first step in establishing a preferred vendor program is an evaluation and selection process.  For each service for which you use vendors, you need to establish a list of vendors to do the work.
  2. It includes a formal mechanism for on-going evaluation of the work done by vendors on a case-by-case basis.  You need to ensure that your list is “fresh”.  Things change.  Staff leaves.  A vendor that is doing great work for you today may not be doing so eight months from now.  You need a mechanism in place to evaluate the work a vendor does on every case.  And that mechanism should include an easy way to incorporate input from end-users. 
  3. It should include scheduled, formal re-evaluations to ensure that you’ve always got the best available vendors on your list.  In addition to evaluating a vendor’s work after each project, the preferred vendor list should be periodically re-assessed.  Are their new vendors that should be added?  Are their better technologies that aren’t offered by the vendors on your list?  Are the vendors on your list still consistently meeting your expectations?  A formal re-review should be a planned, scheduled activity and done once a year or once every eighteen months.

In the next posts in this blog series, I’ll walk you through a step-by-step approach to establishing a preferred vendor program in your firm.

Does your firm have a preferred vendor program?  What are the components of your program?  Please share any comments you might have and let us know if you’d like to know more about an eDiscovery topic.

Working Successfully with eDiscovery and Litigation Support Service Providers: A Centralized Approach
 

Law firms take different approaches to working with vendors.  In some firms, individual litigation teams evaluate, select and manage vendors on a case-by-case basis.  Other firms take a centralized approach where all vendor activities are coordinated and managed by a centralized litigation support department.  And taking that a step further, many firms that use a centralized approach, establish a preferred vendor program.  What works best?  That probably depends on the culture and organization of a law firm. 

For most firms, there is a strong argument to be made for a centralized, preferred-vendor approach.  It has several advantages: 

  1. Vendor evaluation and selection is more likely to be done by those with the most knowledge and broadest experience.  Litigation support professionals are experts in the services provided by litigation support and eDiscovery vendors.  This is what they are trained to do and it is a primary focus of their jobs.
  2. Vendor evaluation is likely to be more thorough and careful.  When vendor evaluation and selection is done when faced with short case deadlines, it may be rushed.  Corners might be cut. 
  3. Working with vendors is likely to be more efficient.  You won’t be reinventing the wheel on every case.  The time-consuming task of evaluating vendors is done once.  On each case, it’s simply a matter of selecting the most appropriate vendor from a list of pre-approved vendors.
  4. You’ll have a stable of good vendors that you trust on-call for rush cases.
  5. Project start-up will be faster and easier.  On each case, you’ll need to communicate case-specific requirements and nuances, but overall expectations, work flow procedures, and communication protocols are already in place.
  6. Expectations regarding deliverables are already in place.  The vendor will know what you expect and will be in a better position to get things right, the first time.
  7. For many tasks, vendors offer pricing based on volume.  You may be able to negotiate preferred-pricing based on overall business with the firm rather than volume on a case-by-case basis.
  8. A centralized, preferred vendor approach will facilitate good working relationships with individuals in the vendor organization.  This can only help with maintaining consistent, high-quality work.

In the upcoming posts in this blog series, we’ll discuss the components of a preferred vendor program and how to go about establishing a program in your firm.

How does your firm work with vendors?  Please share any comments you might have and let us know if you’d like to know more about an eDiscovery topic.

eDiscovery Trends: Wednesday LTWC Sessions
 

As noted yesterday, LegalTech West Coast 2011 (LTWC) is happening this week and eDiscoveryDaily is here to report about the latest eDiscovery trends being discussed at the show.  There’s still time to check out the show if you’re in the Los Angeles area with a number of sessions (both paid and free) available and over 70 exhibitors providing information on their products and services, including (shameless plug warning!) my company, Trial Solutions, which is previewing a redesigned version 10 release of our linear review application, OnDemand®, prior to release this Saturday.

Perform a “find” on today’s LTNY conference schedule for “discovery” and you’ll get 27 hits.  More eDiscovery sessions happening!  Here are some of the sessions in the main conference tracks:

10:30 – 11:45 AM:

E-Discovery and the Cloud

Tom O'Connor, Director, Gulf Coast Legal Technology Center (and previous interviewee on this blog!) will discuss the following:

  • We've all heard of the cloud but are you sure you know what it means? A brief overview
  • New challenges created by the cloud
  • Impact of cloud storage on searchable documents: availability and costs
  • Reasonable discovery practices
  • The basic technical challenges for collecting, reviewing and producing relevant data from the cloud
  • Recent case law
  • Best practices for managing the cloud

Risk & Responsibility vs. Cost Control: Managing E-discovery's Great Balancing Act

Bill Speros, Attorney Consulting in Evidence Management, Speros & Associates LLC will discuss the following:

  • Framing the legal issues–identifying risks and responsibilities for companies and their counsel
  • Negotiations with opposing counsel
  • Custodian selection
  • Data selection
  • Culling options
  • Screen and produce
  • Automated review

2:00 – 3:15 PM:

Social Media and E-Discovery

Joshua A. Engel, Vice President and General Counsel, Lycurgus Group will discuss the following:

  • New challenges created by social media
  • New challenges created by the cloud
  • Impact of cloud storage on searchable documents: availability and costs
  • Reasonable discovery practices
  • Privacy concerns
  • Best practices for social media

Top 5 Ethical Concerns for Lawyers in E-discovery

Brett Burney, Burney Consultants LLC will discuss the following:

  • Appropriately supervise clients' discovery efforts (including potential conflicts around self collection)
  • Avoid conflicts of interest – attorney's and vendor's
  • Appropriately supervise document reviewers
  • Avoid serving as discovery process 30(b)(6) witness
  • Accurately represent clients' data storage paradigm and retrieval/restoration/review expenses

3:45 – 5:00 PM:

Share Point and E-Discovery

Beau Mersereau, Director of Applications, Development and Support, Fish & Richardson, P.C. will discuss the following:

  • An overview of share point and what it means to the legal industry
  • Impact on corporate record keeping
  • More data = more searchable material = higher costs
  • New challenges posed by share point
  • Best practices

The 5 Most Important Things you Need to Consider when Bringing e-Discovery In-house

You have made the decision to in-source certain aspects of the e-Discovery process, or you're considering the potential benefits, but the next step is a challenge. In this session, we will address the five most important things to consider as you take on the responsibilities and risks of e-Discovery internally. We will look through the lenses of both legal and IT, and discuss how best to support the technology and business processes. We also evaluate sourcing models to address the risks. This is an ideal panel for corporate legal departments to attend along with their IT department leaders.

Panelists are: Karen LaFleur, Director of Information Technology and Practice Support, BuchalterNemer, A Professional Corporation; Brett Burney, Burney Consultants LLC; and Lisa K. Clements, Litigation Support Manager, DLA Piper LLP (US).

In addition to these, there are other eDiscovery-related sessions today.  For a complete description for all sessions today, click here.

So, what do you think?  Are you planning to attend LTWC this year?  Please share any comments you might have or if you’d like to know more about a particular topic.

eDiscovery Trends: Welcome to LegalTech West Coast 2011!
 

Today is the start of LegalTech® West Coast 2011 (LTWC) and eDiscoveryDaily is here to report about the latest eDiscovery trends being discussed at the show.  Over the next two days, we will provide a description each day of some of the sessions related to eDiscovery to give you a sense of the topics being covered.  If you’re in the Los Angeles area, come check out the show – there are a number of sessions (both paid and free) available and over 70 exhibitors providing information on their products and services, including (shameless plug warning!) my company, Trial Solutions, which is previewing a redesigned version 10 release of our linear review application, OnDemand®, prior to release this Saturday.

Perform a “find” on today’s LTNY conference schedule for “discovery” and you’ll get 22 hits.  So, there is plenty to talk about!  Sessions in the main conference tracks include:

10:30 – 11:45 AM:

eDiscovery in Action: Reducing the Pain and Increasing the Results

Discusses practices to:

  • Increase defensibility, accountability and transparency across your organization
  • Improve efficiency and reduce the volume of growing, uncontrolled information
  • Reduce eDiscovery costs
  • Maximize the return on your technology investments and improve staff productivity
  • Adopt best practices and automate eDiscovery capabilities

Panelists are: Karen LaFleur, Director of Information Technology and Practice Support, BuchalterNemer, A Professional Corporation; Tom O'Connor, Director, Gulf Coast Legal Technology Center (and previous interviewee on this blog!); and Lisa K. Clements, Litigation Support Manager, DLA Piper LLP (US).

Records Policies, Technology and Processes that Optimize Corporate Compliance and Discovery

Topics discussed include:

  • Discover how to maximize efficiency by managing data in a manner that anticipates requests for ESI
  • Learn tips on how to create, implement and monitor sound and defensible legal hold protocol
  • Analyze how significant cost-savings may be achieved through defensible, repeatable execution of that protocol

Panelists are: Wayne Wong, Managing Consultant, Kroll Ontrack; David Yerich, UnitedHealth Group; Ron Best, Director of Legal Information Systems, Munger Tolles & Olson.  Moderator: Dave Schultz, Manager, Legal Technologies, Kroll Ontrack.

2:00 – 3:15 PM:

Exploring Enterprise Search Technology

Covers how to:

  • Understand the totality of electronic information: documents, websites, emails, tweets, audio and video
  • Automate complex information-centric processes by understanding the meaning of electronically stored information
  • Empower organizations to better address their legal, regulatory and business obligations through evolutionary search technology

Panelists are: Ali Shahidi, Director of Knowledge Management, Bingham McCutchen LLP; Scott A. Preston, Chief Information Officer, Fulbright & Jaworski L.L.P.

Social Media and Discovery: Tales, Trials and Technology

Panelists will:

  • Discuss the impact of social media and the cloud on discovery
  • Hear important questions and implications that must be fully understood before implementing use policies around social media and entrusting data to the cloud
  • Explore data collection, data security, and privacy with regard to social media and the cloud

Panelists are: Wayne Wong, Managing Consultant, Kroll Ontrack; Bianca Dickerson-Willams, CRM, Kroll Ontrack; Jeff Fowler, Counsel, O'Melveny & Myers.  Moderator: Dave Schultz, Manager, Legal Technologies, Kroll Ontrack.

3:45 – 5:00 PM:

Partnering for Success: Inside and Outside Counsel Working Together

Discussion regarding:

  • Linking together inside and outside counsel
  • Improve the early case assessment process Leverage review methods including conceptual search and meaning-based, computer-assisted tagging and coding to reduce cost of review
  • Streamline and simplify the process on a single platform to better comply with the FRCP and help inside and outside counsel avoid sanctions

Panelists are: Jeffrey W. McKenna, Esq., Former Senior Associate, Skadden, Arps, Slate, Meagher & Flom, LLP; Member of the International Association of Privacy Professionals (IAPP); Thérèse P. Miller, Of Counsel, Shook Hardy & Bacon LLP; Bill Speros, Attorney Consulting in Evidence Management, Speros & Associates LLC.

Next Decade of Document Review: Cheaper, Better, Smarter

Topics include:

  • Consider how document review practices have evolved in the past decade
  • Learn how to stop wasting valuable corporate dollars on chaotic document review by utilizing Intelligent Review Technology (IRT), which can reduce the burden and expense of analysis, review and production
  • Discuss cutting-edge cases that highlight the importance of using technology to conduct faster and cheaper discovery

Panelists are: Andrea Marshall, Consultant, Kroll Ontrack; Ron Best, Director of Legal Information Systems, Munger Tolles & Olson; Jeff Fowler, Counsel, O'Melveny & Myers.  Moderator: Dave Schultz, Manager, Legal Technologies, Kroll Ontrack.

In addition to these, there are other eDiscovery-related sessions today.  For a complete description for all sessions today, click here.

eDiscoveryDaily will also be “tweeting” periodically throughout LTWC (this time I mean it!), so feel free to check out our updates at twitter.com/TrialSolutions.

So, what do you think?  Are you planning to attend LTWC this year?  Please share any comments you might have or if you’d like to know more about a particular topic.

eDiscovery Case Law: Cut and Paste Makes the Cut as Evidence
 

In United States v. Lanzon, 2011 WL 1662901 (11th Cir. 2011), the defendant in a criminal case appealed his conviction and raised the issue of whether he prosecution properly authenticated instant messages cut-and-pasted into a Microsoft Word document.

Detective George Clifton, a member of the Miami–Dade Police Department's Sexual Crimes Bureau, posing as a male living with his girlfriend and his girlfriend's 14–year–old daughter, conducted instant message (IM) online chats with Keith Lanzon that led to Lanzon being arrested and charged with violating 18 U.S.C. § 2422(b), which provides that:

Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall be fined under this title and imprisoned not less than 10 years or for life.

Detective Clifton saved these conversations by copying the IM communications and pasting them into a Microsoft Word document, saving the Word document to a “floppy” disc, for printing in transcripts. While Detective Clifton did not save any of the IM conversations in their original format, he did compare the actual IM "chat screens" to the Word document he had created to verify that the Word document exactly matched the IM conversations.

At trial, the prosecution introduced the Word document with the cut-and-pasted IMs, and Lanzon was convicted.  Lanzon appealed to the US Eleventh Circuit Court of Appeals, claiming, inter alia, that the document was improperly admitted, and that the admission of the document violated the Due Process Clause and the Best Evidence Rule.  Lanzon also argued the transcripts violated the rule of completeness in FRE 106 claiming that Detective Clifton failed to include the entire chat transcript, including only the edited portion that supported his case.  FInally, Lanzon claimed that the prosecution failed to properly authenticate the Word document.

The Eleventh Circuit found that Lanzon failed to prove bad faith by the government in failing to preserve the original IMs. The court also rejected Lanzon's rule of completeness argument, finding that “There is no indication that additional parts of the conversation exist.”

As for the failure to authenticate claim, the Eleventh Circuit also rejected that claim, finding that “Evidence may be authenticated through the testimony of a witness with knowledge. FRE 901(b)(1). The proponent need only present enough evidence "to make out a prima facie case that the proffered evidence is what it purports to be.”

A copy of the opinion can be found here.

So, what do you think?  Have you dealt with a case involving evidence cut and pasted into a document?  Please share any comments you might have or if you’d like to know more about a particular topic.

eDiscovery Best Practices: Usefulness of Facebook’s Self Collection Mechanism
 

We’ve written about Facebook a lot on this blog.  Shortly after this blog was launched, we provided information on Facebook’s subpoena policy.  We’ve also talked about the eDiscovery implications associated with the rollout of Facebook’s new email messaging system, dubbed “Facemail”.  And, just last week, we chronicled a case involving Facebook where they were ordered to produce documents instead of just merely providing access to them.  And, we haven’t even mentioned the latest revelations that Facebook may have secretly hired a PR firm to plant negative stories about Google (oops, we just did!).

But perhaps our most popular post regarding Facebook was regarding the self collection mechanism that they rolled out last October, which we found out about via our LegalTech interview with Craig Ball published back in March after our February interview (Craig also wrote an article about the feature in Law Technology News in February).

Now, another article has been written about the usefulness of Facebook’s self collection mechanism (called “Download Your Information”) in the blog E-Discovery Law Alert, entitled How Useful is Facebook's "Download Your Information" Feature in E-Discovery?, written by Patrick V. DiDomenico.

The author of this article conducted a test by downloading his information via the utility, deleting some information from his Facebook profile – “an email message, some wall posts, comments, photos, and even a friend (not a close friend)” – hopefully, he added the friend back.  Then, he downloaded his information again, every day for four days, with no change for the first three days.  On the fourth day, most of the deleted information disappeared from the download, except the email message (which disappeared when he ran the utility one more time).

The conclusion was that the mechanism “does not appear to ‘look back’ and recover deleted information in the user’s account”.  Thoughts:

  • With no change in the download in the first three days, the author notes that “Facebook did not take a fresh snapshot of my account every day – it just re-downloaded the same file three days in a row”.  He doesn’t mention whether he added any content during this time.  It would be interesting to see if that would force a change.
  • I don’t believe that there is any specific documentation from Facebook as to how it handles additions and deletions and how often the snapshot is updated.  If not, it might behoove them to create some, it might save them some subpoena requests.
  • The author notes that “it is inadvisable for lawyers to rely solely on the Download Your Information feature for discovery of an adversary’s Facebook information” as it “gives no assurance that a litigant’s attempt to delete evidence will be revealed”.  On the other hand, it may be still an appropriate mechanism to use for your own discovery to preserve your own information.  Facebook may also store deleted information on backup tapes, so a subpoena could catch your opponent red-handed if you can justify the discovery of those tapes.  Food for thought.

So, what do you think?  Have you had any Facebook discovery requests in your eDiscovery projects?   Please share any comments you might have or if you’d like to know more about a particular topic.

Working Successfully with eDiscovery and Litigation Support Service Providers: Preventing Quality Problems
 

In the past few posts in this series, we’ve discussed ways to minimize the possibility of problems with costs and meeting deadlines.  There are also steps you can take to increase the likelihood of high quality work that will meet your expectations. 

It starts when you are evaluating and selecting a vendor.  Based on your review of a vendor’s qualifications, procedures and technology, along with feedback you’ve received from references, make sure you select a vendor that is likely to do high quality work and that has a good track record. 

Once a project is underway, look at the vendor’s work to ensure it meets your expectations.  This is especially important with work that is labor-intensive.  In fact, there are three levels of quality control that you should be doing:

  1. A review of initial work done by each staff member:  As staff members finish initial batches of work, look at it right away and verify that it is correct.  This way, mistakes made because someone misunderstood instructions can be cleared up very quickly, before a lot of work is done that will need to be re-done.
  2. Ongoing QC of work throughout the project:  Even if everyone on the staff knows how to do the work, that doesn’t mean they will do it right all the time.  Mistakes are inevitable and work should be spot-checked throughout a project to ensure that errors are kept to a minimum.  It’s a good idea to have project staff dedicated to doing on-going quality control reviews.
  3. Random sampling done by senior litigation team members:  In addition to routine quality control done by project staff members, its always a good idea to ask senior members of the litigation team to periodically look at a sampling of the work, to ensure that stakeholder expectations are in sync with the work of the project staff.

What steps do you take to ensure high quality work from a vendor with which you are working?  Please share any comments you might have and let us know if you’d like to know more about an eDiscovery topic.

Working Successfully with eDiscovery and Litigation Support Service Providers: Preventing Unexpected Schedule Problems
 

Of all the problems you might have to report to an attorney, the worst may be that you are going to miss a production deadline.  Deadlines get missed because document or data collections are larger than expected, the task is more difficult than expected, sufficient technical resources aren’t allocated to the project, or the project simply isn’t staffed properly.  Good communication up front with a vendor, and good monitoring throughout a project can minimize the chance of missing deadlines. 

Here are some steps you can take to prevent deadline problems and keep a vendor on track with your schedule requirements:

  • During the vendor evaluation and selection process, get commitments from a vendor on scaling up to accommodate changes in volume.  Ask about their ability to add staff, technical resources, or second shifts to meet deadlines if things get off track.
  • Before signing a contract with a vendor, ask for a schedule that includes weekly estimates of completed work, and that includes expected staffing levels for labor-intensive work.
  • In addition, require that the vendor provide you with weekly status reports that include estimated weekly numbers, actual weekly numbers, estimated to-date numbers, actual to-date numbers, and variances.  This will enable you to see – each week – how the project is going and whether the schedule is slipping.  Carefully review status reports as they are received and speak to the vendor right away if things are getting off-track.  Be proactive in requesting additional resources if the project is getting off-schedule.
  • Require that the vendor notify you in writing – in advance – if a deadline will be missed.
  • When you communicate schedule information to a vendor, build in pad!  For example, give the vendor a deadline well in advance of a production date.
  • Stay in constant communication with the litigation team about discovery issues.  The more notice that you have about additional documents or data, the more notice you can give to the vendor.

What steps do you take to prevent schedule problems with vendor work?  Please share any comments you might have and let us know if you’d like to know more about an eDiscovery topic.