PROCESS

Analysis by Digital Discovery CLE Teaching Fellow Josh Solomon

Cases

Sattar v. Motorola 138 F.3d 1164 (7th Cir.1997)

Plaintiff wanted hard copies of over 200,000 e-mails, since its system couldn’t read defendant’s electronic files. Court affirmed District Court ruling that defendant must equip plaintiff with the capacity to read the files, or pay for half of the hard-copy costs

Anti-Monopoly, Inc. v. Hasbro Inc. 1995 WK 649934, 1995 U.S.Dist LEXIS 1635, S.D.N.Y., 1995

Good analysis of digital discovery issues. Plaintiff moved to compel Hasbro to disclose computer database notwithstanding that Hasbro had already disclosed a paper version. Court found that Plaintiff was certainly entitled to databases even though paper copies had been produced, and producing party can be required to design a computer program to extract the data from its computerized business records, subject to the Court's discretion as to the allocation of the costs of designing such a computer program. Court analyzed time and expense required to create such a database, found that potential benefit to plaintiff was speculative, and ordered parties to meet and discuss. When Plaintiff later moved to compel disclosure without having to pay for it, court held that Plaintiff would be required to pay expenses.

Procter & Gamble Co. v. Haugen, 179 F.R.D. 622, D Utah, 1998

P & G sued competitor and competitor’s distributors for spreading rumors of P & G’s Satanism, specifically alleging defamation, unfair competition, violations of Lanham act, Utah Truth in Advertising Act, etc. Judge Kimball dealt with various motions here, including sanctioning P&G for failing to preserve relevant emails, and allowed P&G to do a keyword search of Defendant’s database on issues concerning agency or control in general, but limited search so that it would not yield general commercial or competitive information.

Simon Property Group L.P. v. mySimon, Inc. 194 F.R.D. 639, S.D.Ind., 2000

On Plaintiff’s motion to compel in trademark case, court held that Plaintiff was entitled to recover deleted computer files, both at office and at home, from employees of Defendant to show that Defendant acted in bad faith in selecting its name. Also held that protective measures would be taken, including appointment of an independent expert to review evidence, to be paid for by Plaintiff.

Scovish v. Upjohn Company 1995 WL 731755, Conn.Super., 1995

Action alleging that Upjohn’s drug Halcion contributed to Plaintiff’s husband’s suicide. Plaintiff seeks discovery of Upjohn’s base-stamp index, database and document retrieval system created to assist Upjohn comply with discovery requests and prepare for litigation. Court found that database was within attorney work-product, but that Plaintiff had substantial need of database and undue hardship would result. Ordered Upjohn to produce database after removing any portions that contain subjective thoughts and opinions.

Superior Consultant Co., Inc. v. Bailey 2000 WL 1279161, E.D.Mich., 2000

Memorandum and order relating to Plaintiff’s complaint alleging that Defendant Bailey, a former employee who had been privy to confidential systems and information, resigned to work for a competitor and assisted the competitor in recruiting other employees from Plaintiff. Charges include breach of employment agreement, tortious interference, breach of fiduciary duty, and violation of Michigan Uniform Trade Secrets act. Memo grants Plaintiff’s motion for Temporary Restraining Order and orders, inter alia, that Defendant Software Technologies Corporation make a backup for Plaintiff’s counsel of Bailey’s laptop and any other computer hard drives he had access to.

Fullerton v. Prudential Ins. Co. 194 F.R.D. 100, S.D.N.Y., 2000

Employment discrimination case. Affirms magistrate judge’s decision that when Prudential produced privileged email documents about its internal investigation of gender discrimination, it thereby waived attorney-client privilege and work-product privilege of issues within the emails.

Crown Life Ins. Co. v. Craig 995 F.2d 1376, C.A.7 (Il.), 1993

Insurer brought action against agent, and agent counter-claimed against insurer, claiming he was owed commissions. Affirms trial court’s decision to sanction insurer and enter default judgment against insurer when it failed on several occasions to comply with discovery order requesting raw data from database.

In re Dow Corning Corp. 250 B.R. 298, Bkrtcy.E.D.Mich., 2000

Federal government, in responding to discovery request for medical records stored in computer database, directed plaintiffs to warehouses around the world where they were kept. Court ruled this was not acceptable, that this did not satisfy their obligation to make the material available at an acceptable place.

Articles

Joan E. Feldman and Rodger I. Kohn, "Collecting Computer Based Evidence," N.Y.L.J. (Jan. 26, 1998).

· Hidden data
· Good discovery practices for both sides

Sheindlin and Rabkin, "Electronic Discovery in Federal Civil Litigation: Is Rule 34 up to the Task?" 41 B.C. L. Rev 327 (2000).

· Hidden data
· Uncertainty about what type of electronic data is covered by any given discovery request/order
· Electronic vs. paper submission of discovery information
· Difficulty of shifting electronic discovery costs

Lacouture, Peter V. "Discovery and the use of computer-based information in litigation." Rhode Island Bar Journal 45 (December 1997), 9.

· Good discovery practice for plaintiffs-use of interrogatories

Johnson-Laird, Andrew. "Smoking guns and spinning disks." Computer Lawyer 11 (August 1994), 1.

· Good discovery practice for plaintiffs-use of experts and well-crafted requests
· Hidden data Process of responding to requests

The Linnen Story: Excerpt from Mundy, Alicia. "Dispensing with the Truth"