Get the Data that Cures Your Headache Collecting the Right Data Effectively and Efficiently Speakers: Megan Kelberman Michael Quartararo Jonathan Rowe Robert Rudnicki

The Headache Brokerage of America (“BOA”) – 1000 financial advisors, 200 offices in 15 states Class action lawsuit against BOA claiming “unreasonable” processing fees Plaintiff requests documents and correspondence for the time period the fees were first instituted to the present date which discuss or refer to processing fees

Aspirin Plan and scope the collection Identify key custodians and sources of relevant data Outsourcing vs In-house IT resources for collection? Proportionally, burden and control Limit custodians and sources Cooperation with opposing counsel Use a model ESI agreement/stipulation Targeting, searching and sampling Document your collection Complete chain of custody Maintain collection logs/reports

Software Demonstration Harvester eDiscovery Collection Options Keyword filter laptop, desktop, server, Outlook, Exchange, and webmail accounts (i.e. Gmail, Yahoo, Hotmail) Dedupe and deNIST files Preserve file timestamps and metadata Create electronic Chain of Custody Harvester Portable Send Self-Collection hard drive kits which include job instructions that automate defensible custodian backup Harvester Server Remotely collect eDiscovery data from custodian computers across a network Monitor job progress in real-time and generate progress reports from a central location